Privacy Policy

Effective Date: July 2026

Last Updated: July 2026

Pamoja is operated by Impact Microfinance Limited, a company incorporated and licensed to operate in the United Republic of Tanzania.

Pamoja respects your privacy and is committed to protecting your personal information. This Privacy Policy explains how Pamoja collects, uses, stores, shares, and protects personal information when you access or use our mobile application, web platform, USSD services, and related digital channels.

This Privacy Policy is designed in accordance with the laws of the United Republic of Tanzania, including the Personal Data Protection Act, 2022, and incorporates internationally recognized data protection principles.

1. Scope of this Privacy Policy

This Privacy Policy applies to all users of Pamoja, including:

• Individual members
• Community groups
• Associations
• Cooperatives
• Branches
• Organizations
• Administrators
• Financial institutions and partners using the platform

By using Pamoja, you agree to the collection and processing of your information as described in this Privacy Policy.

2. Information We Collect

Personal Information

• Full name
• Date of birth
• Gender
• Nationality
• Identification information
• Photographs
• Signatures
• Biometric information where legally permitted

Contact Information

• Mobile phone number
• Email address
• Residential address
• Geographic location information

Membership Information

• Community membership records
• Group participation
• Roles and responsibilities
• Contributions and participation history
• Governance records

Financial Information

• Savings records
• Contributions
• Shares and capital records
• Loan information
• Repayment history
• Mobile money transactions
• Payment instructions
• Financial account references

Technical Information

• Device identifiers
• Browser information
• Operating system
• IP address
• Network information
• Device location where authorized

3. Information We Collect Automatically

• Login information
• Session information
• Device activity
• Platform usage statistics
• Error logs
• Security monitoring data
• Performance information

This information helps us maintain security, improve performance, and provide better services.

4. How We Use Information

• Create and manage user accounts
• Verify identity
• Support community operations
• Facilitate governance and participation
• Process financial transactions
• Manage savings, shares, loans, and contributions
• Provide customer support
• Improve products and services
• Conduct analytics and reporting
• Prevent fraud and abuse
• Comply with legal and regulatory obligations

5. Legal Basis for Processing

• User consent
• Performance of contractual obligations
• Compliance with legal requirements
• Legitimate business interests
• Protection of users and communities
• Regulatory and supervisory requirements

6. Financial Services and Payments

Pamoja may facilitate transactions involving mobile money operators, banks, microfinance institutions, savings groups, cooperatives and other regulated financial service providers.

Certain financial services may be governed by additional agreements and regulatory requirements. Pamoja acts as a technology platform and may process transaction information necessary to support such services.

7. Information Sharing

We do not sell personal information.

We may share information with:

• Licensed financial institutions
• Mobile money providers
• Payment service providers
• Regulatory authorities
• Technology service providers
• Cloud hosting providers
• Auditors and compliance service providers
• Authorized community administrators
• Strategic partners where necessary

8. International Data Transfers

Pamoja may process and store information within the United Republic of Tanzania, in international cloud environments, and through approved third-party service providers.

Where information is transferred outside Tanzania, appropriate safeguards will be implemented to protect personal information.

9. Cloud Infrastructure and Data Security

• Encryption
• Access controls
• Authentication mechanisms
• Audit trails
• Security monitoring
• Data backup procedures
• Disaster recovery processes
• Secure cloud infrastructure

Despite our efforts, no system can guarantee absolute security.

10. Data Retention

We retain personal information only for as long as necessary to provide services, meet contractual obligations, comply with legal requirements, satisfy regulatory obligations, resolve disputes, and protect our legitimate interests.

11. User Rights

• Access personal information
• Request correction of inaccurate information
• Request deletion of certain information
• Restrict processing
• Withdraw consent
• Object to certain processing activities
• Request portability of eligible information

12. Cookies and Analytics

Pamoja may use cookies, session technologies, analytics tools, performance monitoring tools, and security monitoring technologies.

13. Children's Information

Pamoja does not knowingly collect personal information from children except where authorized by parents or guardians, required by community programs, or permitted by applicable laws.

14. Third-Party Services

Pamoja may integrate with mobile money operators, banking systems, payment gateways, identity verification providers, communication platforms, and cloud infrastructure providers.

15. Changes to this Privacy Policy

Updated versions will be published on the platform and become effective upon publication unless otherwise specified. Continued use of Pamoja constitutes acceptance of any revised Privacy Policy.

16. Contact Information

17. Governing Law

This Privacy Policy shall be governed by and interpreted in accordance with the laws of the United Republic of Tanzania, including the Personal Data Protection Act, 2022, and other applicable regulations.