1. Scope and law

This policy covers ODELPay HUB services: tuition checkout, student portal, school admin, receipts, OpenPayGB card and wallet, LiveStore merchant shops, payment links, bills & airtime, Stars tip/reward activity, On/Off and Dex balances, developer dashboard, ODELPay HUB Copilot, Telegram bot and Mini App, public visitor analytics, and related APIs. AssessmentVerse OS and the URAPearls Clicker app (/clicker/privacy) have their own privacy notices.

We process personal data in line with Uganda's Data Protection and Privacy Act, 2019 and the Data Protection and Privacy Regulations, 2021, and with other laws that apply where an institution operates.

2. Who is responsible

Each institution (school, university or business) decides what student, parent and staff data it records in its workspace and is the data controller for those records. The platform operator processes that data on the institution's behalf to run the service, and is the controller for platform accounts, OpenPayGB, Dex, analytics and support data.

Where registration with the Personal Data Protection Office (PDPO) is required, the operator maintains it. Institutions are responsible for their own registration.

3. Data we collect

We collect information you provide (name, email, phone, programme or class, institution, merchant shop profiles and product listings), payment metadata (amounts, rails, status, references, billed vs paid fee lines), admin and developer credentials (hashed passwords, API key prefixes), and technical logs (user agent, webhook delivery records).

Admission documents uploaded by institution staff may be read by an automated scan to pre-fill student details.

TON wallet addresses and transaction memos may be stored for payment matching. Telegram identifiers are used when you sign in via the bot or Mini App. Utility bill and airtime top-up requests store account or MSISDN identifiers needed to complete the purchase.

OpenPayGB card records may include activation period, fee category, fee snapshots, and balance history needed for closed-loop ledger integrity. Identity information may be collected where anti-money-laundering rules or our payment providers require it.

Anonymous site analytics: we set a visitor cookie and record page views (path, referrer, timestamp). We do not store raw IP addresses. We keep a one-way hash of the visitor cookie, optional country/city from the CDN edge, and aggregate unique-visitor and page-view counts. Copilot chats may be stored to provide history and improve help articles.

4. Children's data

School workspaces hold records of pupils who are children. Institutions collect and enter this data and are responsible for obtaining the consent of a parent or guardian where the law requires it. We use children's data only to provide fee, receipt and school-administration services, never for marketing, and we do not target digital-asset features at children.

5. How we use data

To process payments and receipts, operate multi-tenant workspaces and merchant storefronts, meet legal and anti-fraud obligations, provide support (including ODELPay HUB Copilot), send transactional email (e.g. verification, receipts, fulfilment notes), publish optional public visitor counts when the platform operator enables that toggle, and improve the knowledge base.

Automated tools such as the admission-letter scan only suggest information; a person at the institution reviews and confirms it. We do not make decisions that significantly affect you based solely on automated processing.

Master admins may export operational data subject to backup and partner API policies. Demo login password hints may be published on lobbies only when Master Admin marks a demo slot ACTIVE for public hint display.

6. Marketing

We send marketing messages only where permitted, and every marketing email, SMS, WhatsApp or Telegram message includes a way to opt out. You may also write to us at any time asking us to stop using your personal data for direct marketing; we will stop and reply in writing within 14 days.

7. Sharing and transfers

We share data with payment service providers (Mbiyo, LivePay, Relworx, VixonPay, TON network), hosting providers, and email delivery (e.g. Resend) only as needed to deliver the service or meet legal obligations. We do not sell personal data.

Our hosting and database providers may store or process data outside Uganda. We use providers that apply appropriate security and contractual safeguards so that data receives a level of protection comparable to Ugandan law.

Partner integrators with scoped API keys access only the data permitted by their key scope and organization binding. Telegram receives only what is required to deliver bot messages or Mini App sessions you initiate.

8. Retention & security

Payment and receipt records are retained for accounting, dispute resolution and legal record-keeping. API secrets are stored hashed; plaintext keys are shown once at creation.

We use HTTPS, access controls, audit logs, and tenant isolation on workspaces. No method of transmission over the Internet is 100% secure; we monitor for and respond to incidents and notify affected parties and authorities where the law requires.

9. Your rights

Under the Data Protection and Privacy Act, 2019 you may ask to access your personal data, have it corrected, blocked or erased, object to processing that causes unwarranted damage or distress, stop direct marketing, and not be subject to decisions based solely on automated processing. Contact your institution admin for records it controls, or platform support for platform accounts. Some records must be kept for legal or audit reasons.

If you are not satisfied with our response, you may complain to the Personal Data Protection Office (https://www.pdpo.go.ug).

1. Scope and law

This policy covers ODELPay HUB services: tuition checkout, student portal, school admin, receipts, OpenPayGB card and wallet, LiveStore merchant shops, payment links, bills & airtime, Stars tip/reward activity, On/Off and Dex balances, developer dashboard, ODELPay HUB Copilot, Telegram bot and Mini App, public visitor analytics, and related APIs. AssessmentVerse OS and the URAPearls Clicker app (/clicker/privacy) have their own privacy notices.

We process personal data in line with Uganda's Data Protection and Privacy Act, 2019 and the Data Protection and Privacy Regulations, 2021, and with other laws that apply where an institution operates.

2. Who is responsible

Each institution (school, university or business) decides what student, parent and staff data it records in its workspace and is the data controller for those records. The platform operator processes that data on the institution's behalf to run the service, and is the controller for platform accounts, OpenPayGB, Dex, analytics and support data.

Where registration with the Personal Data Protection Office (PDPO) is required, the operator maintains it. Institutions are responsible for their own registration.

3. Data we collect

We collect information you provide (name, email, phone, programme or class, institution, merchant shop profiles and product listings), payment metadata (amounts, rails, status, references, billed vs paid fee lines), admin and developer credentials (hashed passwords, API key prefixes), and technical logs (user agent, webhook delivery records).

Admission documents uploaded by institution staff may be read by an automated scan to pre-fill student details.

TON wallet addresses and transaction memos may be stored for payment matching. Telegram identifiers are used when you sign in via the bot or Mini App. Utility bill and airtime top-up requests store account or MSISDN identifiers needed to complete the purchase.

OpenPayGB card records may include activation period, fee category, fee snapshots, and balance history needed for closed-loop ledger integrity. Identity information may be collected where anti-money-laundering rules or our payment providers require it.

Anonymous site analytics: we set a visitor cookie and record page views (path, referrer, timestamp). We do not store raw IP addresses. We keep a one-way hash of the visitor cookie, optional country/city from the CDN edge, and aggregate unique-visitor and page-view counts. Copilot chats may be stored to provide history and improve help articles.

4. Children's data

School workspaces hold records of pupils who are children. Institutions collect and enter this data and are responsible for obtaining the consent of a parent or guardian where the law requires it. We use children's data only to provide fee, receipt and school-administration services, never for marketing, and we do not target digital-asset features at children.

5. How we use data

To process payments and receipts, operate multi-tenant workspaces and merchant storefronts, meet legal and anti-fraud obligations, provide support (including ODELPay HUB Copilot), send transactional email (e.g. verification, receipts, fulfilment notes), publish optional public visitor counts when the platform operator enables that toggle, and improve the knowledge base.

Automated tools such as the admission-letter scan only suggest information; a person at the institution reviews and confirms it. We do not make decisions that significantly affect you based solely on automated processing.

Master admins may export operational data subject to backup and partner API policies. Demo login password hints may be published on lobbies only when Master Admin marks a demo slot ACTIVE for public hint display.

6. Marketing

We send marketing messages only where permitted, and every marketing email, SMS, WhatsApp or Telegram message includes a way to opt out. You may also write to us at any time asking us to stop using your personal data for direct marketing; we will stop and reply in writing within 14 days.

7. Sharing and transfers

We share data with payment service providers (Mbiyo, LivePay, Relworx, VixonPay, TON network), hosting providers, and email delivery (e.g. Resend) only as needed to deliver the service or meet legal obligations. We do not sell personal data.

Our hosting and database providers may store or process data outside Uganda. We use providers that apply appropriate security and contractual safeguards so that data receives a level of protection comparable to Ugandan law.

Partner integrators with scoped API keys access only the data permitted by their key scope and organization binding. Telegram receives only what is required to deliver bot messages or Mini App sessions you initiate.

8. Retention & security

Payment and receipt records are retained for accounting, dispute resolution and legal record-keeping. API secrets are stored hashed; plaintext keys are shown once at creation.

We use HTTPS, access controls, audit logs, and tenant isolation on workspaces. No method of transmission over the Internet is 100% secure; we monitor for and respond to incidents and notify affected parties and authorities where the law requires.

9. Your rights

Under the Data Protection and Privacy Act, 2019 you may ask to access your personal data, have it corrected, blocked or erased, object to processing that causes unwarranted damage or distress, stop direct marketing, and not be subject to decisions based solely on automated processing. Contact your institution admin for records it controls, or platform support for platform accounts. Some records must be kept for legal or audit reasons.

If you are not satisfied with our response, you may complain to the Personal Data Protection Office (https://www.pdpo.go.ug).