Privacy Policy

1. Introduction

Holocorp Ltd ("we", "us", "our") operates the Moneta Pay POS platform, including the website at moneta-pay.app, the customer portal at portal.moneta-pay.app, the POS client software, and the management dashboard (collectively, the "Service").

This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you use our Service. By using the Service, you agree to the collection and use of information in accordance with this policy.

2. Information We Collect

Account Information

When you register for an account, we collect:

• Business name, address, and contact details
• Account holder name and email address
• Phone number
• Tax identification number (e.g., KRA PIN) for fiscal compliance features

Transaction Data

The POS system processes and stores:

• Order details (items, quantities, prices, timestamps)
• Payment information (payment method, amount, M-PESA transaction references)
• Staff activity (wait staff assignments, cashier sessions, void records)
• Expense and deposit records

Transaction data is stored locally on your POS server. If you opt into the Managed Backup add-on, encrypted snapshots are transmitted to our secure cloud storage.

Technical Data

We automatically collect:

• Hardware ID (for licence binding)
• Server version and configuration metadata
• Licence validation requests (timestamp, hardware fingerprint)
• IP address and network information during VPN registration

Website Analytics

Our marketing website may use standard analytics to understand visitor behavior. No personally identifiable information is shared with third-party analytics providers.

3. How We Use Your Information

We use the information we collect to:

• Provide the Service — process orders, generate reports, manage licences, and deliver features you've subscribed to
• Licence management — validate licences, enforce capacity limits, and process renewals
• Fiscal compliance — submit invoices to tax authorities on your behalf when the ESD feature is enabled
• Customer support — diagnose issues, provide technical assistance, and respond to inquiries
• Service improvement — understand usage patterns to improve the product
• Billing — process subscription payments and manage your account
• Communication — send service updates, licence expiry reminders, and support responses

4. Data Storage and Security

On-Premise Data

Your POS transaction data (orders, payments, staff records, expenses) is stored locally on your restaurant's server. We do not have access to this data unless you explicitly grant access through the Remote Access VPN feature or the Managed Backup add-on.

Cloud Data

Account information, licence records, and billing data are stored on our secure cloud infrastructure. Managed Backup snapshots are stored in encrypted cloud storage with a 3-week retention period.

Security Measures

We implement industry-standard security measures including:

• Encrypted communications (TLS/HTTPS) for all cloud services
• WireGuard encryption for Remote Access VPN connections
• Ed25519 digital signatures for licence files
• Encrypted database backups (when using Managed Backup)
• Role-based access control within the dashboard

5. Data Sharing and Disclosure

We do not sell your data. We may share information in the following circumstances:

• Tax authorities — fiscal receipt data is submitted to your country's tax authority (e.g., KRA, URA) when the ESD feature is enabled, as required by law
• Subscription payment processors — when you pay us for your subscription, billing details and transaction references are shared with the processor handling it: Paystack (cards and M-PESA, Kenya) or Paddle (cards outside Kenya, acting as merchant of record). We never store full card numbers; card details are entered directly with the processor
• Payment integrations you enable — separately from your subscription, the Service can connect to mobile money providers so your restaurant can see and reconcile payments from your diners: Safaricom Daraja and KopoKopo for M-PESA. Here we act on your behalf using credentials you supply, and the data exchanged is your own transaction data. See section 5a
• Legal requirements — when required by law, court order, or governmental authority
• Market Intelligence — if you opt into the Market Intelligence add-on, anonymized and aggregated expense data may be used for cross-restaurant benchmarking. No individually identifiable data is shared.

5a. Payment Integrations

These are distinct from how you pay us. A payment integration lets your restaurant receive and reconcile money from its own customers; your subscription payments to us are covered in section 5 above.

• Safaricom Daraja — M-PESA Express (STK push) and the Buygoods/Paybill transaction feed, so a diner's payment can be matched to an open order automatically
• KopoKopo — Buygoods payment notifications, used the same way

You supply the credentials for these and can revoke them at any time; doing so stops the integration immediately and removes our ability to read that feed. We store the transaction references needed to match a payment to an order, and the till or shortcode the payment arrived on. We do not initiate payouts, move funds between accounts, or change your settlement details.

Money from these integrations settles directly to your Safaricom or KopoKopo account. It never passes through us.

6. Data Retention

• On-premise data — retained on your server indefinitely, under your control
• Account data — retained while your account is active and for 12 months after account closure
• Backup data — retained for 3 weeks (rolling), then permanently deleted
• Licence records — retained for the duration of the licence plus 12 months

7. Your Rights

Whoever and wherever you are, you have the right to:

• Access — ask what personal data we hold about you and get a copy
• Rectification — have inaccurate or incomplete data corrected
• Erasure — have your account and associated personal data deleted, subject to records we must keep by law (see section 6)
• Portability — receive your data in a machine-readable format, or export your transaction data from the POS at any time
• Restriction and objection — ask us to stop or limit a particular use, including any processing based on legitimate interests
• Withdraw consent — where we rely on consent, withdraw it at any time without affecting processing already carried out
• Opt out of non-essential communications
• Complain to a supervisory authority (see section 7c)

To exercise any of these, email [email protected]. We respond within 30 days and will not charge you for a reasonable request. We may ask you to confirm your identity before releasing data, so that we do not disclose your information to someone else.

7a. Legal Framework and Lawful Basis

Holocorp Ltd is the data controller for the personal data described in this policy. We process it under Kenya's Data Protection Act, 2019, and — where we offer the Service to customers in the European Economic Area or the United Kingdom — the General Data Protection Regulation (GDPR) and UK GDPR.

We rely on these lawful bases:

Where we rely on legitimate interests we have considered the impact on you, and you can object at any time using the contact above.

7b. International Transfers

Our infrastructure is hosted in Europe and Kenya. Where personal data moves between jurisdictions, or to one of the processors named in section 5, that transfer is covered by the receiving party's own compliance programme and, for transfers out of the EEA or UK, by Standard Contractual Clauses or an equivalent safeguard. For transfers out of Kenya we rely on the conditions in Part VI of the Data Protection Act, 2019.

Paddle, our Merchant of Record for customers outside Kenya, acts as an independent controller for the payment data it collects. Its handling of that data is governed by Paddle's Privacy Notice.

7c. Complaints

If you think we have handled your data wrongly, please tell us first — most problems are a misunderstanding we can fix quickly. You can also complain directly to a regulator:

• Kenya — Office of the Data Protection Commissioner (ODPC), odpc.go.ke
• EEA — the supervisory authority in your country of residence
• United Kingdom — Information Commissioner's Office, ico.org.uk

Using one of these does not require you to come to us first, and does not affect any other legal remedy.

7d. Breach Notification

If a breach of personal data is likely to result in a risk to your rights, we will notify the relevant supervisory authority within 72 hours of becoming aware of it, and notify you without undue delay where the risk is high.

8. Children's Privacy

Our Service is not directed to individuals under the age of 18. We do not knowingly collect personal information from children.

9. Changes to This Policy

We may update this Privacy Policy from time to time. We will notify you of material changes by posting the updated policy on our website and updating the "Last updated" date. Continued use of the Service after changes constitutes acceptance of the updated policy.

10. Contact Us

If you have questions about this Privacy Policy, contact us at:

Holocorp Ltd
P.O. Box 12901 00100
Nairobi, Kenya
Email: [email protected]