1. Who is responsible for your data
SMS YANU is operated by Deltacomm (Deltacomm), registered office CG443-303 Off Viphya Avenue, Chigumula, Blantyre, Postal Code 312238, P.O. Box 2617, BT, Malawi. For any question about your personal data, contact [DATA PROTECTION CONTACT] at [email protected].
Registration with the data protection authority, if required: [REGISTRATION DETAILS OR "NOT APPLICABLE"].
2. What we collect
- Account details: name, organisation, email address, phone number and login details.
- Verification details: [IDENTITY OR BUSINESS DOCUMENTS COLLECTED, IF ANY].
- Messaging data: recipient numbers, message content, sender names, delivery reports and timestamps.
- Payment data: top-up amounts, references and invoices. When online payment is used, card and mobile money details are entered with our payment gateway, not on our pages. [CONFIRM WHAT PAYMENT DATA IS RECEIVED FROM THE PAYMENT GATEWAY]
- Technical data: IP addresses, browser type and security logs.
Our websites and dashboards use Google Tag Manager to measure how pages are used. Google may set cookies and receive technical data such as your IP address and the pages you visit.
3. Why we use it
- To provide the Service and deliver your messages.
- To bill you and keep financial records.
- To keep the Service secure and prevent fraud and misuse.
- To meet legal obligations.
- To contact you about your account and the Service.
Legal basis for each purpose: [LEGAL BASIS UNDER APPLICABLE LAW].
4. Who we share it with
To deliver messages we pass recipient numbers and content to mobile networks and messaging partners. We also use service providers for hosting and payments: [CATEGORIES OF RECIPIENTS]. We do not sell personal data.
5. International transfers
Messages to destinations outside Malawi, and some hosting, may involve transfers outside Malawi. [COUNTRIES AND SAFEGUARDS]
6. How long we keep it
- Message content: [RETENTION PERIOD]
- Delivery records and logs: [RETENTION PERIOD]
- Financial records: [RETENTION PERIOD]
- Account details after closure: [RETENTION PERIOD]
7. Your rights
Depending on the law that applies, you may have the right to access, correct or delete your personal data, to object to or restrict its use, and to complain to the data protection authority. To make a request, contact [email protected]. [RESPONSE TIMES AND AUTHORITY CONTACT DETAILS]
8. Messages you send
When you send messages through the Service, you decide who receives them and what they say. You are responsible for having a lawful basis to message your recipients. [CONTROLLER AND PROCESSOR ROLES FOR CUSTOMER MESSAGING DATA]
9. Security
We use technical and organisational measures to protect personal data. [SUMMARY OF MEASURES]
10. Changes
We may update this notice and will show the date of the latest version at the top.