Privacy Policy

1. What this covers

This policy explains what data XenFi Systems Limited ("XenFi", "we") collects when you use our websites and platform, why we collect it, who we share it with, and the choices you have. It applies to network operators with XenFi accounts, members of the XenFi Partner Program ("partners"), and visitors to our websites.

We handle personal data in line with the laws that apply to us, including Uganda's Data Protection and Privacy Act, 2019 and Kenya's Data Protection Act, 2019.

2. What we collect

From network operators

• Account data: your name, contact details and business information when you sign up.
• Billing data: transactions processed through your networks, including payment references from providers such as M-PESA, MTN Mobile Money and Airtel Money, used to run your billing and settle your balances.
• Network data: router status, session and usage records needed to authenticate users, enforce plans and show you analytics.

From partners

• Account data: your name, email address, phone number and country.
• Identity data: your date of birth, the type and number of your identity document, and images of it, used to verify who you are.
• Payout data: the mobile money or bank account you withdraw to, and the name registered on it.
• Program data: your referrals, commission, rewards, withdrawals, and the requests you send to businesses.

From everyone

• Technical data: logs, IP address, device and browser information that keep the platform secure and working.
• Referral data: if you arrive through a partner's link or QR code, the partner's code, how you arrived, and, when you sign up, your IP address and browser details (see section 5).

3. How we use it

We use data to run the service you signed up for: authenticating sessions, processing payments, showing analytics, providing support and improving the platform. We also use it to run the Partner Program, which means attributing businesses to the partners who introduced them, calculating and paying commission, verifying partners' identities, and preventing fraud and abuse, including self-referral, duplicate accounts and false claims. We do not sell personal data.

4. Sharing

Data is shared only where running the service requires it: with payment providers to process transactions and payouts, with infrastructure providers that host the platform, with email and SMS providers that deliver our messages, and with authorities where the law demands it. Your customers' data stays yours; we process it to provide the service to you.

Sharing with the partner who introduced your business

If your business is attributed to a XenFi partner, because you signed up through their link or code, confirmed that they introduced you, or our staff linked your business to them after reviewing the introduction, we share limited information with that partner so they can help you keep your network running and selling:

• your business name, plan and country, and when you joined XenFi;
• the name and phone number of the business owner on the account;
• the names of your hotspots, and whether your business and each hotspot are active, including how long since the last sale;
• the commission the partner has earned from your business.

We do not share with partners your password, the personal data of the people who use your network, or your payment and settlement details. Partners must use this information only to help you with XenFi, keep it confidential, and delete it when they stop being linked to your business. If a partner misuses it, or you would like us to stop sharing it, contact us and we will review your request.

Confirmation requests

A partner may ask us to confirm that they introduced a business which joined XenFi before the Partner Program started. When they do, we email the business owner, telling them the partner's name, and record the answer. The partner does not see your email address unless they already had it, and we screen every request.

Sharing about partners

When a partner asks a business to confirm an introduction, we show that business the partner's name. We never show a partner's identity documents or payout details to anyone outside XenFi, except payment providers and authorities as described above.

5. Cookies and referral tracking

We use cookies that are needed to keep you signed in and to protect the platform. When you open a partner's referral link or scan their QR code, we also store a cookie in your browser holding that partner's code and how you arrived. It lasts 30 days and is used only to credit the partner if you create a XenFi business account. We do not use it for advertising. You can delete it at any time by clearing your browser data, in which case no partner will be credited for your signup.

When a business account is created, we record the IP address and browser details used, to check for self-referral and other abuse of the Partner Program. These checks can lead a person at XenFi to review a referral before commission is paid.

6. Security and retention

Traffic to the platform is encrypted, access to production data is restricted, and payment credentials are handled by the payment providers rather than stored by us. Identity documents are stored with restricted access. We keep data for as long as your account needs it or the law requires, then delete or anonymise it. Records of commission, payouts and fraud reviews may be kept after an account closes, for as long as financial, tax and anti-fraud obligations require.

7. Your choices

You can access and correct your account data from the dashboard, and you can ask us to export or delete data connected to your account. Closing your account starts deletion under our Terms of Service, less what payment, tax and anti-fraud law require us to keep. Partners can find the equivalent terms in the Partner Program Terms.

8. Changes to this policy

When this policy changes in a way that matters, we will tell you through the dashboard or the contact details on your account.

9. Contact

Privacy questions and requests can be sent through the contact page at xenfisystems.com/contact, and we will respond from there.