Privacy policy

This policy explains what personal data Debian POS holds, why, where it is kept and the rights you have over it under Kenya's Data Protection Act, 2019. It covers the debianpos.com website and the Debian POS service that shops use to run their tills and back offices.

1. Who we are

Debian POS is run by [Company name to be confirmed], registration number [Registration number to be confirmed], of [Registered address to be confirmed]. For anything about your personal data, write to [Data protection email to be confirmed].

2. Two roles: ours and the shop's

When a shop uses Debian POS to record its own customers, sales and staff, the shop decides what it collects and why, so the shop is the data controller and Debian POS processes that data on the shop's behalf and only on its instructions. If you are a customer of a shop that uses Debian POS, ask that shop first about your data; we will help it answer you.

For the people who open and run accounts with us, and for anyone who contacts us through this website, Debian POS is the data controller.

3. What we collect

About the people who use Debian POS

• Names, email addresses, phone numbers and the branches and roles staff work in.
• Passwords and approval PINs, kept only as one-way hashes we cannot read.
• When people sign in, from which network address, and what they change that matters, such as voids, refunds and price changes, kept in each shop's audit log.

What shops record in Debian POS

• Their customers' names, phone numbers, email and delivery addresses, purchases, loyalty points and whether they agreed to marketing texts.
• Sales, payments and receipts, including M-Pesa details Safaricom reports for a payment: the M-Pesa code, the amount, the payer's name and a phone number Safaricom may mask.
• Card and mobile money payments taken through Pesapal are processed by Pesapal; Debian POS never sees or stores card numbers.

From this website

• What you send through the contact form: your name, shop, email, phone and message, with the network address it came from.
• No analytics or advertising trackers. The site sets only the cookies it needs to work (see section 9).

4. Why we use it, and on what basis

• To provide the service a shop signed up for (performance of a contract): running the till, keeping stock and records, sending receipts and the texts a shop chooses to send.
• To bill shops for Debian POS (contract, and the law on keeping financial records).
• To keep the service and its data safe (legitimate interests): sign-in records, the audit log, backups and checks against fraud such as fake M-Pesa messages.
• To answer you when you contact us (legitimate interests, or the steps you ask for before signing up).
• Marketing texts a shop sends its customers go only to customers who agreed; the shop records and honours that choice, and every promotional text can be stopped.

We do not sell personal data, and we do not use shops' records for our own marketing.

5. Who else handles it

We use a small number of providers, each bound to protect the data and use it only to do their part:

• Amazon Web Services, which hosts Debian POS and its backups and sends its emails.
• Safaricom, for M-Pesa payments a shop takes through its own M-Pesa number.
• Pesapal, for card and mobile money payment links, and for shops paying their Debian POS subscription.
• Africa's Talking, for the texts a shop sends from its own account.
• Kenya Revenue Authority, once eTIMS invoicing is available, for the invoices the law requires a shop to send.

We disclose data to authorities only when the law requires it.

6. Where it is kept

Debian POS runs in Amazon Web Services' Cape Town region in South Africa, so personal data is stored outside Kenya, within Africa. We transfer it there under the safeguards the Data Protection Act requires, with encryption and contractual commitments from Amazon Web Services. [Counsel to confirm the transfer basis and any notice to the Data Commissioner.]

7. How long we keep it

• A shop's records are kept while its account is open. When a shop asks to close it, we give it an export and delete its records within 90 days, except what the law requires us to keep, such as financial and tax records, which are kept for up to five years.
• Backups roll over on their own: daily copies for 35 days, monthly copies for a year, and earlier versions of files for 30 days. Deleted data leaves the backups as they expire.
• Server logs are kept for 30 days. Website enquiries are kept for two years after we last hear from you.

8. How we protect it

• Every connection is encrypted, and so is the stored data and every backup.
• Each shop's records are walled off from every other shop's in the database itself, not only in the app.
• Staff see only what their role and branches allow, sensitive actions need a manager's PIN, and the audit log cannot be edited.
• We test that backups can be restored, every month.

If a breach puts your data at risk, we will tell the Data Commissioner within 72 hours of learning of it and, where the risk is real, tell you too.

9. Cookies

The site and the app set only cookies they cannot work without: one keeps you signed in, one protects forms from being sent by another site. There are no analytics, advertising or tracking cookies, so we do not ask for consent to them.

10. Your rights

Under the Data Protection Act you may ask us to tell you what we hold about you and give you a copy, correct it, delete it, or stop or limit how we use it, and you may withdraw consent you gave. Write to [Data protection email to be confirmed]; we answer within 30 days, free of charge. If you are a shop's customer, the shop answers first and we help it.

If you are not satisfied, you may complain to the Office of the Data Protection Commissioner at odpc.go.ke.

11. Children

Debian POS is a business service and is not meant for children. We do not knowingly collect children's data except as a shop's customer records.

12. Changes to this policy

When we change this policy we update the date at the top, and we tell shops by email before a change that affects them takes effect.