In plain language

We collect only the information necessary to help you manage community contributions. We never sell your personal data to third parties. Your money stays between you and your community — we just help you track it.

No. IIntroduction

Welcome to Tshelo ("we," "our," or "us"). We are committed to protecting your personal information and your right to privacy. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you use our mobile application and website (collectively, the "Service").

By using Tshelo, you agree to the collection and use of information in accordance with this policy. If you do not agree with our policies and practices, please do not use our Service.

No. IIInformation we collect

Information you provide

Data typeExamplesPurpose
Account infoName, phone number, emailAccount creation & identification
Mobile moneyProvider selection, phone numberPayment display to contributors
Fund infoNames, purposes, target amountsService functionality
ContributionsAmounts, dates, member detailsTracking contributions
ExpensesDescriptions, amounts, receiptsTracking expenses
CommunicationsMessages, notes, thank-yousIn-app communication

Information collected automatically

Data typeExamplesPurpose
Device infoDevice type, OS, app versionService optimisation
Usage dataFeatures used, time spentImproving the Service
SMS dataMobile money confirmations onlyAuto-detect payments
Log dataIP address, browser typeSecurity & troubleshooting

Information related to premium features

When you purchase Tokens or use premium features, we collect:

  • Transaction details (amount, date, payment method)
  • Token balance and usage history
  • Feature usage patterns for premium services

We do not store full payment card numbers or mobile money PINs. Payment processing is handled by third-party providers.

No. IIIHow we use your information

We use the information we collect to:

  • Create and manage your Tshelo account
  • Process and track contributions within your funds
  • Detect mobile money payments and automatically update contribution records
  • Generate reports and export fund summaries
  • Send notifications about fund activity
  • Calculate and display Trust Scores on profiles
  • Process Token purchases and maintain your Token balance
  • Facilitate communication between fund members
  • Provide customer support
  • Improve and optimise our Service
  • Train and improve our AI models (using anonymised data only)
  • Detect and prevent fraud or abuse
  • Comply with legal obligations

No. IVHow we share your information

With other fund members

When you join or create a fund, certain information is visible to other members:

  • Your name and profile information
  • Your contribution amounts and dates
  • Your role (organiser or contributor)
  • Messages and reactions you post

This transparency is a core feature of Tshelo, designed to build trust within your community groups.

With service providers

Provider typePurposeData shared
Cloud hostingStore data securelyAll data (encrypted)
Payment processorsToken purchasesTransaction data
SMS providersNotificationsPhone number, message
AnalyticsUnderstand usageAnonymised data
AI servicesReceipt scanningReceipt images

What we do not do

  • Sell your personal information to third parties
  • Share your data with advertisers
  • Use your financial data for credit scoring or lending decisions
  • Share individual contribution data with anyone outside your fund

Legal requirements

We may disclose your information if required by law, court order, or government regulation, or if we believe disclosure is necessary to protect our rights, your safety, or the safety of others.

No. VAI and automated processing

How we use AI

Receipt scanning. We process receipt images to extract vendor names, amounts, dates, and categories. Receipt images may be stored temporarily for processing. We do not share your receipt images with third parties except our AI service providers.

SMS payment detection. With your permission, we read SMS messages from mobile money providers. We use pattern matching and AI to identify payment confirmations. We only process messages from recognised providers (Orange Money, MyZaka, Smega). Personal messages are never read or stored.

Trust Score calculation. We use automated algorithms to calculate Trust Scores. Scores are based on objective factors (verification status, fund history). No human reviews individual Trust Scores.

Your rights regarding automated processing

  • You can request human review of any automated decision that affects you
  • You can opt out of AI-powered features (though this limits functionality)
  • You can request deletion of data used in AI processing

AI training

  • We may use anonymised, aggregated data to improve our AI models
  • Your personal information is never used in identifiable form for AI training
  • Receipt images used for training have all personal information removed

No. VIData security

We implement appropriate technical and organisational measures to protect your personal information:

MeasureDescription
EncryptionData encrypted in transit (TLS) and at rest
Access controlsLimited employee access, role-based permissions
MonitoringSystems monitored for suspicious activity
Secure developmentSecurity built into development process
Regular auditsPeriodic security assessments

However, no method of transmission over the Internet is 100% secure. While we strive to protect your information, we cannot guarantee absolute security.

No. VIIData retention

Data typeRetention periodReason
Active account dataWhile account is activeService provision
Contribution records7 years after fund closesFinancial record-keeping laws
Expense records & receipts7 years after fund closesAudit trail requirements
Token purchase history7 yearsTax and financial compliance
Deleted account data90 days then permanently deletedRecovery period
Support communications3 yearsService improvement
AI training dataIndefinitely (anonymised only)Model improvement
SMS processing logs30 daysTroubleshooting

Data deletion

When you delete your account:

  • Profile information is deleted within 90 days
  • Your contributions in others' funds remain (attributed to "Deleted User")
  • Funds you created may be transferred to a co-organiser or closed
  • Some data may be retained for legal compliance

No. VIIIYour rights and choices

RightDescriptionHow to exercise
AccessSee what data we have about youSettings → Download My Data
CorrectionFix inaccurate dataEdit in app or contact us
DeletionRequest deletion of your dataSettings → Delete Account
PortabilityGet your data in a usable formatSettings → Download My Data
Withdraw consentStop marketing, SMS readingSettings → Privacy
Opt-outNon-essential communicationsUnsubscribe link or Settings

No. IXSMS and notification permissions

Our app may request permission to:

  • Read SMS messages. To automatically detect incoming mobile money payment confirmations. We only read messages from recognised mobile money providers (Orange Money, MyZaka, Smega) and do not access personal messages.
  • Send notifications. To alert you about new contributions, fund invitations, and reminders.

These permissions are optional. You can disable them at any time through your device settings, though this may limit certain features.

No. XCountry-specific privacy rights

South Africa (POPIA compliance)

If you are located in South Africa, you have additional rights under the Protection of Personal Information Act (POPIA):

  • Right to be notified when your personal information is collected
  • Right to access your personal information
  • Right to request correction of inaccurate information
  • Right to request deletion of your personal information
  • Right to object to processing of your personal information
  • Right to submit a complaint to the Information Regulator

Information Regulator contact: www.inforegulator.org.za

Kenya (Data Protection Act 2019)

If you are located in Kenya, you have rights under the Data Protection Act, 2019:

  • Right to be informed of the use of your personal data
  • Right to access your personal data
  • Right to object to processing
  • Right to correction of false or misleading data
  • Right to deletion of false or misleading data

Office of the Data Protection Commissioner: www.odpc.go.ke

Zimbabwe, Ghana, Nigeria, Uganda

We comply with applicable data protection requirements in these jurisdictions and respect your rights to:

  • Access your personal data
  • Request correction or deletion
  • Object to certain processing activities

Contact us for specific information about your rights in your jurisdiction.

No. XIInternational data transfers

Your information may be transferred to and processed in countries other than your own. When we transfer data internationally, we ensure appropriate safeguards are in place:

  • Standard contractual clauses where required
  • Data processing agreements with all service providers
  • Encryption of data in transit and at rest

No. XIIChildren's privacy

Tshelo is not intended for use by individuals under the age of 18. We do not knowingly collect personal information from children. If you are a parent or guardian and believe your child has provided us with personal information, please contact us immediately.

No. XIIIChanges to this policy

We may update this Privacy Policy from time to time. We will notify you of any material changes by:

  • Posting the new Privacy Policy on this page
  • Updating the "Last updated" date
  • Sending you a notification through the app or email for significant changes

Your continued use of the Service after changes constitutes acceptance of the updated policy.

No. XIVThird-party links

Our Service may contain links to third-party websites or services. We are not responsible for the privacy practices of these third parties. We encourage you to review their privacy policies before providing any personal information.

No. XVContact us

If you have questions or concerns about this Privacy Policy or our data practices, please contact us:

Email: tshelo@data-sentinels.com

Tshelo is a product of Data Sentinels (Pty) Ltd, Gaborone, Botswana.

To exercise your rights

  • In-app: Settings → Privacy → Download My Data / Delete Account
  • Email: tshelo@data-sentinels.com with subject "Data Rights Request"
  • We will respond within 30 days (or sooner if required by local law)