This Privacy Policy ("Policy") explains how Peculiar Enterprises Ltd (the "Company", "we", "us" or "our") collects, uses, discloses and protects information in connection with the Peloo platform (the "Service"). The Company is the owner and operator of the Service, is incorporated in the United Republic of Tanzania under registration number 174005729, and has its registered office at Dar Free Market, Kinondoni, Dar es Salaam, Tanzania. By accessing or using the Service you acknowledge the practices described in this Policy.
The Company acts in two capacities. For information about our subscribing customers and their staff — for example account, billing and usage information — the Company is the data controller. For personal data that a subscribing customer (the "Customer") uploads or processes through the Service about its own borrowers, guarantors and other individuals ("Borrower Data"), the Company acts only as a data processor on the Customer's behalf. In that case the Customer is the data controller and is responsible for the lawfulness of that data, for obtaining any required consents, and for responding to the requests of the individuals concerned. This Policy primarily describes the Company's own processing; the Customer's own privacy notice governs its relationship with its borrowers.
When a Customer registers or is onboarded, we collect organisation details and the names, email addresses, telephone numbers and login credentials of Authorised Users, together with role and permission settings.
We collect the information needed to invoice and collect Fees, such as billing contact details, plan selection and payment records. Card or mobile-money credentials are handled by our payment providers; we do not store full payment-instrument details on our own systems.
On the instruction of, and as a processor for, our Customers, the Service stores and processes data those Customers enter about their borrowers and related parties — which may include names, contact details, national identification numbers, addresses, loan, repayment and collateral records, and uploaded documents. The Company does not determine the purposes of this processing and uses it only to provide the Service.
We automatically collect technical data such as IP address, device and browser type, log and diagnostic data, audit-trail events, and information about how the Service is accessed and used, in order to operate, secure and improve the Service.
We collect the content and metadata of communications you send us, such as support requests and correspondence.
We use information, where we act as controller, on the lawful bases of performing our contract with the Customer, our legitimate business interests, compliance with legal obligations, and, where required, consent. Purposes include:
The Service uses cookies and similar technologies that are necessary for it to function, such as maintaining your signed-in session and remembering preferences, and to understand usage. Disabling essential cookies may prevent the Service from working correctly. Where required by law, we will seek consent for non-essential cookies.
We do not sell personal data. We share information only as follows:
The Service and its supporting infrastructure may be hosted or accessed in countries other than your own, and information may therefore be transferred to and processed outside the United Republic of Tanzania. Where we transfer personal data across borders, we take steps intended to ensure it remains protected in a manner consistent with this Policy and with applicable law.
We retain information for as long as it is needed to provide the Service, for the duration of the Customer's Subscription, and thereafter for as long as necessary to comply with our legal, accounting, tax and regulatory obligations, resolve disputes and enforce our agreements. Borrower Data is retained on behalf of the Customer for the duration of the engagement, after which, following a reasonable period, it may be deleted or anonymised. The Customer is responsible for exporting its data before its Account is closed.
We implement technical and organisational measures designed to protect information against unauthorised access, alteration, disclosure or destruction, including access controls, encryption in transit and audit logging. However, no method of transmission or storage is completely secure, and we cannot guarantee absolute security. Customers and Authorised Users are responsible for safeguarding their login credentials and for configuring access appropriately; the Company is not responsible for loss arising from a Customer's failure to do so.
Subject to applicable law, including the Personal Data Protection Act, 2022 of the United Republic of Tanzania, individuals may have rights to access, correct, update, delete, restrict or object to the processing of their personal data, and to data portability. Where the Company acts as controller (for example for Authorised-User account data), such requests may be made to us at [email protected], and we will respond as required by law. Where the Company acts only as a processor of Borrower Data, requests must be directed to the relevant Customer, who is the controller of that data; we will support that Customer in responding as our agreement with them requires.
The Service is intended for use by businesses and their staff and is not directed to children. We do not knowingly collect personal data directly from children. Any information about individuals under the age of majority that a Customer processes through the Service is the Customer's responsibility as controller.
The Service may link to or interoperate with third-party websites and services that we do not control. This Policy does not apply to those third parties, and we are not responsible for their privacy practices. We encourage you to review their policies.
We may update this Policy from time to time. The current version will be posted with a revised effective date, and material changes will be notified by reasonable means. Continued use of the Service after the effective date constitutes acceptance of the updated Policy.
This Policy is governed by the laws of the United Republic of Tanzania and should be read together with the Company's Terms and Conditions.
For questions, concerns or requests regarding this Policy or your personal data, contact Peculiar Enterprises Ltd, Dar Free Market, Kinondoni, Dar es Salaam, Tanzania, by email to [email protected], by telephone to +255 759 891 571, or via pel.tz. Where required by law, you also have the right to lodge a complaint with the competent data-protection authority in the United Republic of Tanzania.