PRIVACY POLICY FOR ASANTECHEM POS SYSTEM Effective Date: October 1, 2026 Last Updated: October 1, 2026 -------------------------------------------------------- 1. INTRODUCTION Welcome to Asantechem Point of Sale (POS) System ('Asantechem', 'we', 'us', or 'our'). We provide a point-of-sale software solution designed for merchants, retail stores, and businesses ('Merchants' or 'Clients') to process sales transactions, manage inventory, issue digital receipts, and track business analytics. We respect your privacy and are committed to protecting the personal and operational data processed through our platform. This Privacy Policy explains how we collect, use, disclose, and safeguard information when Merchants, store staff, and end-customers interact with our software, mobile applications, hardware integrations, and web dashboard. This policy is designed to comply with applicable data protection legislation, including the Kenya Data Protection Act, 2019 and international privacy standards. 2. ROLES IN DATA PROCESSING - Asantechem as a Data Processor: When processing sales data, transaction histories, customer databases, and employee details uploaded by a Merchant using the Asantechem POS, the Merchant acts as the Data Controller, and Asantechem acts as the Data Processor. - Asantechem as a Data Controller: Asantechem acts as the Data Controller for personal data directly collected from Merchants for account administration, billing, subscription management, customer support, and system security. 3. INFORMATION WE COLLECT A. Merchant & Account Information: Business name, registration, KRA PIN, account credentials, POS staff PINs, and M-Pesa / Bank details. B. Transaction & Customer Data: Products purchased, prices, taxes, payment method (Cash, M-Pesa, Card), customer contact data for e-receipts, and payment transaction reference codes. C. Technical & Usage Information: Device IDs, hardware serial numbers, OS versions, IP addresses, crash logs, and audit trails. 4. HOW WE USE INFORMATION To provide core POS functionality, process payments via STK push, facilitate eTIMS/KRA tax compliance integrations, maintain system security, provide support, and offer sales analytics. 5. LAWFUL BASIS FOR PROCESSING Contractual necessity, legal obligations (tax & audit laws), legitimate business interests, and explicit user consent. 6. SHARING & DISCLOSURE OF INFORMATION We do not sell data. We share data strictly with required partners: Payment Service Providers (M-Pesa/Banks), Tax Authorities (KRA eTIMS), cloud infrastructure providers, and law enforcement if legally compelled. 7. DATA SECURITY SAFEGUARDS Protected using TLS/SSL end-to-end encryption, Role-Based Access Control (RBAC), immutable system audit logs, and continuous cloud backups. 8. DATA RETENTION & ERASURE Data is kept while the merchant account is active. Upon cancellation, data is retained for 30–90 days for export before secure deletion, excluding statutory accounting records. 9. DATA SUBJECT RIGHTS Users have the right to access, rectify, or request erasure of personal data under the Kenya Data Protection Act, 2019. 10. CONTACT US Email: privacy@asantechem.com | Support: support@asantechem.com