Privacy Policy

1. Introduction

ZERA POS is committed to protecting the privacy and personal data of its users, clients, and partners. This Privacy Policy explains how we collect, use, disclose, store, and protect personal data in accordance with the Uganda Data Protection and Privacy Act, 2019.

By using our services, platforms, or systems, you acknowledge and accept the practices described in this Privacy Policy.

2. Who We Are

ZERA POS provides ICT and digital platform services, including messaging solutions, billing and customer management systems, and related technology services to businesses and service providers.

For purposes of applicable data protection law, ZERA POS acts primarily as a Data Controller, and in certain circumstances as a Data Processor where services are provided strictly on the documented instructions of clients.

3. Personal Data We Collect

We may collect and process the following categories of personal data:

• Names
• Mobile phone numbers
• Email addresses
• User account and profile details
• Login credentials and authentication data
• Billing, invoicing, and transaction records
• Message delivery logs and communication metadata
• Sender ID and messaging identifiers
• IP addresses and system access logs
• Customer support and correspondence records

4. Categories of Data Subjects

The personal data we process relates to:

• Business clients and their authorized users
• End users and recipients of electronic communications
• Employees and contractors
• Technical administrators and support users

5. Purpose of Processing

Personal data is processed for the following purposes:

• Provision, operation, and management of digital platforms and services
• Client onboarding, user authentication, and account administration
• Delivery and monitoring of electronic communications
• Billing, invoicing, and financial reconciliation
• Service usage auditing, reporting, and analytics
• Fraud detection, misuse prevention, and platform security
• Customer support and dispute resolution
• Compliance with legal, regulatory, and contractual obligations

6. Lawful Basis for Processing

We process personal data based on one or more of the following lawful bases:

• Performance of a contract
• Consent of the data subject where applicable
• Compliance with legal or regulatory obligations
• Legitimate business interests, including system integrity, security, and fraud prevention

7. Source of Personal Data

Personal data is obtained from:

• Clients during onboarding and use of our services
• Clients acting as data controllers who provide personal data for processing
• System-generated data arising from platform usage and transactions

8. Data Sharing and Disclosure

Personal data may be shared with:

• Licensed telecommunications operators and upstream service providers strictly for service delivery
• Regulatory authorities where disclosure is required by law
• Third-party service providers engaged under appropriate data processing agreements

ZERA POS does not sell personal data or share it for unsolicited marketing purposes.

9. Cross-Border Data Transfers

Personal data is primarily processed and stored within Uganda. Where cross-border access or transfers occur for infrastructure management or technical support purposes, appropriate safeguards are implemented in line with applicable data protection legislation.

10. Data Retention

Personal data is retained only for as long as necessary to fulfill the purposes for which it was collected, comply with legal and regulatory requirements, resolve disputes, and maintain audit trails. Specific retention periods are defined in internal retention schedules.

11. Data Security

ZERA POS implements appropriate technical and organizational measures to safeguard personal data, including:

• Role-based access controls
• Authentication and authorization mechanisms
• Secure hosting environments
• System monitoring and audit logging
• Periodic access reviews
• Incident detection and response procedures

12. Data Subject Rights

Data subjects have the right to:

• Access their personal data
• Request correction of inaccurate or incomplete data
• Request deletion of personal data where applicable
• Object to or restrict processing
• Withdraw consent where processing is based on consent

Requests may be submitted using the contact details below.

13. Complaints

Data subjects may raise concerns or complaints directly with ZERA POS. They also retain the right to lodge a complaint with the Personal Data Protection Office of Uganda.

14. Contact Information

For inquiries, requests, or concerns relating to this Privacy Policy or personal data processing, contact:

15. Changes to This Policy

This Privacy Policy may be updated periodically. Updated versions will be made available through our platforms or upon request.