Privacy Policy

Introduction

This privacy policy applies to TechMasters' website and all other websites owned and operated by TechMasters Zambia Limited (collectively, "We", "Us", "Our"). We are dedicated to protecting and upholding the privacy of persons who visit and interact with our websites. This Privacy Policy discloses the way in which we collect, use and protect your personal information in accordance with the Zambian Data Protection Act 3, 2021

Collection of Personal Information

Techmasters will process your personal information in order to facilitate your transactions. All such processing shall be in accordance with applicable laws, including the Data Protection Act No. 3 of 2021 (the "DPA"), and Techmasters' privacy policies, the latest copy of which is available on websites.

We collect your information in the following ways;

• Information you provide directly: This may include your personal information (name, email address, phone number, etc), company information, and any other information relevant to providing you, our services.
• Information collected automatically: This may include your IP address, browser type, operating system, device information, browsing activity on our website, and other usage data.
• Information from third parties: In line with our internal controls, we may collect information about you or your company from public sources or third-party service providers to the extent permitted by law.

We will not sell, share, or rent this information to any third parties. We collect information from our users on our site. With your consent you will receive information regarding new features, services and special offers.

How We Use Your Personal Information

We use your personal information for the following purposes:

• To facilitate and complete any TechMasters transactions at your request, including but not limited to payments or services that may involve our regulated products.
• To accurately respond to your inquiries and fulfil your requests for support.
• With regards to automatically collected data, to analyze and improve the functionality, content, and user experience of our website and services.
• To comply with applicable legal and regulatory obligations.
• To enable us share marketing and promotional communications, where you have provided your consent.

Cookies

Our website uses cookies, which enables us to automatically collect information and data about website users, however, this is optional as you have the option to either accept, decline or partially accept to use cookie. Cookies may, however, be necessary to provide you with certain features available on the website. If you disable cookies, you may not be able to use these features, and your access to the website will be limited

Sharing Your Personal Information

This section outlines how and with whom your personal information may be shared.

At TechMasters we are committed to maintaining the confidentiality and security of your personal information. We only share your data when it is lawfully, necessary, and proportionate to the purpose for which it was collected.

1. Internal Sharing Within the TechMasters Limited.

We may share your personal data within Techmasters and its subsidiaries, including but not limited to TechPay. For the following purposes:

• Customer service and support functions;
• IT maintenance, software updates, and system enhancements;
• Consolidated reporting, compliance, and internal audits.

All data sharing is governed by strict internal access protocols and data processing agreements to ensure your information is protected.

2. With Third-Party Service Providers

We engage with selected third-party vendors to support our business operations. These may include:

• Cloud storage and IT infrastructure providers;
• Payment processors and transaction verification partners;
• Identity verification, KYC/AML solution providers;
• Professional advisors such as auditors, legal or HR service consultants, and tax advisors.

Personal information with third parties will be shared where we engage them to assist us in providing our services, however this will only be done were you explicitly consent and to the extent required by law.

All of our third parties are bound by our confidentiality, security and data privacy policies and are only permitted to process your information in accordance with our instructions.

3. Legal and Regulatory Disclosures

We may be required to share your personal data with government agencies, regulators, law enforcement, or other public bodies under the following circumstances:

• To comply with legal obligations, including statutory reporting;
• In response to a lawful request, court order, or legal process;
• To report suspicious activity in compliance with anti-money laundering (AML) and counter-terrorist financing (CFT) obligations.

Such disclosures will be made in accordance with applicable data protection laws and only when strictly necessary.

4. With Your Consent

In cases where your explicit consent is required, we will ensure you are fully informed before sharing your information. This may include:

• Marketing activities with third-parties;
• Referral programs or customer testimonials;
• Use of biometric data for access controls or security systems.

5. Cross-Border Transfers

If it becomes necessary to transfer your personal data outside Zambia, we will ensure that:

• The receiving country complies with Zambia's Data Protection Laws (DPA) and General Data Protection Regulation (GDPR);
• Standard contractual clauses or other legal safeguards are in place;
• You are notified where required by law.

6. Business Transfers

In the event of a merger, acquisition, restructuring, or sale of all or a portion of our business, your personal information may be transferred to the new entity, subject to data protection guarantees consistent with this policy.

Automated Decision Making

Techmasters, may use automated systems and profiling techniques to support the efficient delivery of services and to meet compliance obligations.

We recognise the importance of transparency and fairness when using such technologies and are committed to ensuring that individuals are not unfairly impacted.

What Is Automated Decision-Making?

Automated decision-making refers to decisions made about an individual solely by technological means without human involvement. These systems analyse data using algorithms to make predictions or conclusions.

Examples may include:

• Fraud or suspicious activity detection
• Transaction risk scoring
• Automated onboarding risk classification
• Creditworthiness assessments (where applicable)

What Is Profiling?

Profiling involves the automated processing of personal data to evaluate certain personal aspects of an individual, particularly to:

• Analyse or predict work performance
• Economic situation
• Personal preferences
• Interests
• Reliability or behaviour

For example, Techmasters may use transaction behaviour to assess risk profiles or flag anomalies based on set thresholds.

Why We Use Automated Systems

TechMasters may implement these tools for the following legitimate purposes:

• To meet anti-money laundering (AML) and counter-terrorist financing (CFT) obligations under local and international regulations
• To enhance security and protect users from fraud or unauthorized access
• To streamline onboarding processes and improve operational efficiency
• To comply with Visa/Mastercard or financial institution rules where applicable

Safeguards in Place

To ensure fairness, transparency, and legal compliance, we have implemented the following safeguards:

• Human Oversight: Any automated decision that could significantly affect an individual is subject to human review and can be challenged.
• Explainability: We maintain documentation that explains how decisions are made by automated tools.
• Periodic Audits: Our systems, including tools such as AML Watcher, G2, and the internal case management system, are periodically tested for accuracy, bias, and regulatory compliance.
• User Rights: Individuals have the right to:
  • Request human intervention in automated decisions
  • Express their point of view
  • Contest the decision

These rights can be exercised by contacting our Data Protection Officer using the details provided in this policy.

No Sole Automated Decisions on Sensitive Matters

We do not make any decision solely through automated means that produces legal or similarly significant effects on an individual, especially when dealing with special categories of personal data, without appropriate safeguards or explicit consent.

Your Rights

You have the following rights under the DPA;

• The right to access your personal information.
• The right to rectify inaccurate or incomplete personal information.
• The right to erasure of your personal information.
• The right to restrict the processing of your personal information.
• The right to object to the processing of your personal information.
• The right to data portability.

Access to Your Personal Information

To exercise any of these rights, including the right to request the deletion of your personal data, you are required to submit a formal request to TechMasters, our appointed data processor and system operator, in accordance with the Zambia Data Protection Act, PCI DSS, and ISO 27001 standards. Requests for deletion or data access must be sent to: support@techpay.co.zm . All valid requests will be addressed within a reasonable timeframe, in line with applicable regulations.

Data Retention

We will retain your information for as long as it is necessary to fulfil the purposes for which it was collected. We will retain and use your information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.

Data Security

We take appropriate technical and organizational measures to protect your personal information from unauthorized access, disclosure, alteration, or destruction. However, no website or internet transmission is completely secure, and we cannot guarantee the security of your information.

Behavioral Advertising

We partner with third parties to either display advertising on our web site or to manage our advertising on other sites. Our third-party partners may use technologies such as cookies to gather information about your activities on this website in order to provide you with advertising based your browsing activities and interests.

Log Files

We gather certain information automatically and store it in log files. This information may include internet protocol (IP) addresses, browser type, internet service provider (ISP), referring/exit pages, operating system, date/time stamp, and/or clickstream data. We do not link this automatically collected data to other information we collect about you. We may combine the log information with other information we collect about you. This is done in order to improve marketing, analytics, site functionality and the services we offer you.

Links

This website contains links to other sites. Kindly note that TechMasters' is not responsible for the privacy practices of other sites. We encourage our users to be aware when opting to leave our site. We encourage our users to read the privacy statements of each site that collects personal information. This privacy statement applies solely to information collected by this Website.

Social Media Widgets

Our website includes Social Media Features, such as the Facebook Like button. These Features may collect your IP address, what page you are visiting on our site, and may set a cookie to enable the Feature to function properly. Social Media Features and Widgets are either hosted by a third party or hosted directly on our Site. Your interactions with these Features are governed by the privacy policy of the company providing it.

Sale of Our Company

In the event that the company is sold, or a significant portion of our assets is sold to another company, all customer data including financial records and consumer information collected on Techpay may be transferred to the new company. You will be notified via email of any such change in ownership or control of your personal information

Changes to Our Privacy Policy

We reserve the right to modify this privacy statement from time to time. We will ensure that significant amendments are communicated to Data Subjects via email, posting on the website, or other such methods.