Privacy Policy

NebaPay and your community's board operate as joint controllers of your personal data:

• NebaPay is the platform operator. We design the system, host the database, and define how data flows between parties.
• Your community's board (Chairperson, Secretary, Treasurer, and other authorised roles) decides who joins, sets levies, manages finances, and is responsible for how the platform is used inside the community.

Where this Policy refers to "we", we mean NebaPay specifically. Where a decision is made by the community's board, responsibility rests with the board.

• Identity — Full name, email address, mobile phone number. Used to create your account and identify you in the community registry.
• Property — Plot number, sector, zone, usage type (residential / business), ownership type (owner / tenant). Used to attach you to the right plot for billing and administration.
• KYC documents — Front and back of a national ID or other identity document, where your community requires KYC. Stored securely and accessed only for review.
• Household — Names and details of family members linked to your plot, emergency contacts. Visible only to you and authorised board members.
• Financial — Levy payment history, payment status, carried arrears, advance payments, credit months, waivers granted, payment receipts.
• Plot-debt acceptance — The amount you accepted joint liability for at registration, and the timestamp of acceptance.
• Information supplied by your community board (data migration) — When a community joins NebaPay with existing records, your board may provide your name, phone number, plot number, outstanding balance, and months paid in advance from its previous records (typically a spreadsheet). This data is loaded during onboarding, becomes part of your registry and financial record, and is attached to your account when you register. You should verify it at first login and raise any discrepancy with your board.
• Audit trail — Records of every action you or your board take in the system, each with timestamp, actor, and a structured details record.
• Support & communication — Support tickets you raise, messages you send through the in-app inbox, push notifications you receive.
• Device & usage — Push notification tokens, app session logs, basic device information, and timestamps of actions.

What we do not collect. NebaPay does not collect your mobile money credentials, bank passwords, or biometric data. We do not track your location, scan your contacts, or read messages outside the app. We do not sell your data to advertisers or any third party.

• Performance of contract — to operate the NebaPay platform under the Terms & Conditions you agreed to. This covers identity, property, financial, audit, and plot-debt acceptance data.
• Your consent — for sensitive collections such as KYC documents and emergency contacts. You can withdraw consent through your community's board, but doing so may limit your ability to use parts of the platform.
• Legitimate interest — for the audit trail, security logs, and aggregated metrics used for community compliance grading. We rely on this basis only where it does not override your rights.
• Legal obligation — where Malawian law requires us to retain or disclose information (for example, financial recordkeeping obligations).

Inside your community — different board roles see different data, enforced by row-level security in our database:

• Chairperson — full visibility of community member data, finances, and audit logs.
• Treasurer — financial records, payments, expenses, disbursements, and KYC submissions.
• Secretary — registry, approvals, member statuses, compliance items.
• Other board roles — limited or read-only access defined by your community.
• Plot mates — other residents on your plot can see your name and the plot's payment status.
• Other residents — see only community-public information.

Service providers — we share data strictly to operate the platform with: Supabase (database hosting), OneKhusa (payment processing — membership identifier, amount, and reference only), Resend (transactional email delivery), and Expo (push notifications — message and device token only). Each provider processes data only on our instructions.

Legal and security disclosures — we may disclose data when required by law, by a valid court order, or to protect the safety, rights, or property of NebaPay, your community, or other users.

• Active accounts — data is retained for as long as your account is active in any community.
• Suspended accounts — data is retained while suspended; access is blocked but records are preserved.
• Moved-out accounts — data is retained as part of the community's permanent financial record. Move-out records, payments, and clearance certificates are kept indefinitely for audit purposes.
• Audit logs — retained indefinitely as part of the community's compliance trail. They cannot be deleted through the app.
• Financial records — retained indefinitely to satisfy financial recordkeeping obligations.
• KYC documents — retained for as long as you are a member of a community that requires KYC. On deletion request, KYC document files are erased; the metadata of approval/rejection is retained in audit form.
• Support tickets and push tokens — retained for as long as your account is active, then archived.
• Deletion requests — when granted, your personal data is erased per Section 7. Audit log entries that reference you may be retained in pseudonymised form to preserve community financial integrity.

NebaPay's database, file storage, and serverless functions are hosted on Supabase. Supabase, in turn, runs on cloud infrastructure that may be located outside Malawi. By using NebaPay you acknowledge and consent to your data being stored and processed at the location of our hosting provider, subject to the safeguards described in this Policy.

• Right of access — you can request an export of your personal data through the in-app Data Privacy screen. The export includes your profile, payment history, and activity logs.
• Right to correction — you can update your name, email, and phone number through Edit Account. Property fields can be updated by your board on your request.
• Right to deletion — you can submit a data deletion request through the in-app Data Privacy screen. Where granted, your personal data is erased and your email is permanently blocked from re-registering with the same community. Records necessary for community financial integrity may be retained in pseudonymised form.
• Right to portability — your exported data is delivered in PDF form so you can keep it for your own records.
• Right to object and withdraw consent — where we rely on your consent (for example, KYC), you can withdraw it through your community board.
• Right to complain — contact your community board first. For platform-level concerns, contact NebaPay through the in-app support feature or at the contact address on the NebaPay website.

• Transport encryption — all communication between your device and NebaPay's servers is encrypted in transit.
• Database row-level security — our database enforces access rules per user, constrained by role and community.
• Restricted secrets — sensitive credentials (such as OneKhusa API keys) are stored in a secrets table accessible only by privileged backend processes.
• Signed URLs for documents — KYC document files are held in a private storage bucket and accessed only via short-lived signed URLs issued to authorised reviewers.
• Authentication enforcement — when an account is suspended, the user's session is invalidated and re-authentication is blocked until reactivation.
• Audit logging — sensitive actions are logged with actor, timestamp, and details for accountability.
• No third-party marketing — we do not embed advertising or marketing trackers in the platform.

The NebaPay mobile app uses a small amount of on-device storage to remember your authentication session, your most recent community context, and a cache of recently viewed records to keep the app responsive. The web administration dashboard uses session cookies to keep board members signed in. We do not use third-party advertising cookies or trackers.

NebaPay is intended for use by adults aged 18 and over. We do not knowingly collect data from children. Where KYC is required, the document you upload must indicate adult status.

Where data is transferred to processors located outside Malawi (for example, our cloud hosting provider), we rely on contractual safeguards with those providers to maintain appropriate data protection. By using NebaPay you consent to such transfers, subject to those safeguards.

We may update this Privacy Policy from time to time to reflect changes in the platform, applicable law, or our practices. When we publish a new version, the version number is incremented and the effective date is updated. You will be required to review and accept the updated Policy at your next login. Continued use of the platform after an updated version is published constitutes acceptance.

For questions about this Policy or how your data is handled, contact your community board first. For platform-level concerns, contact NebaPay through the in-app support feature or at the contact address published on the NebaPay website.