Privacy Policy

1. Introduction

Tuma Hela, a DBA of Tessaract Holdings LLC and its affiliated companies ("Tuma Hela," "we," "us," or "our") are committed to protecting your privacy and personal information. This Privacy Policy explains how we collect, use, share, and protect your personal information when you use our mobile application, website, and digital financial services (collectively, the "Services").

Our Services include digital money remittance, mobile money transfers, cryptocurrency wallet integration, bank account deposits, merchant payments, bill payments, airtime top-ups, and related financial technology services accessible through the Tuma Hela mobile application ("App").

2. Who We Are

Tuma Hela is a DBA of Tessaract Holdings LLC, a financial technology company specializing in digital remittance and mobile money services. Our registered address is:

We operate across multiple jurisdictions to provide cross-border financial services to diaspora communities and their families.

Our group of companies includes entities registered in various jurisdictions where we operate, each serving as data controllers for personal information processed in their respective regions. Tessaract Holdings LLC serves as the primary data controller for the purposes described in this Privacy Policy.

3. Information We Collect

The information we collect varies depending on how you interact with our Services and may include:

A. Personal Identification Information

• Full name, date of birth, place of birth, nationality, gender
• Email address, phone number, residential address
• Government-issued identification documents (passport, driver's license, national ID)
• Taxpayer identification numbers, Social Security numbers (where applicable)
• Biometric data including facial recognition for identity verification
• Employment information, income verification documents

B. Financial Information

• Bank account details and statements
• Mobile money wallet information (M-Pesa, MTN Mobile Money, etc.)
• Cryptocurrency wallet addresses and transaction history
• Credit history and affordability assessments
• Transaction patterns and financial behavior data
• Source of funds documentation

C. Technical and Device Information

• Device identifiers, IP addresses, operating system information
• App usage data, screen interactions, feature utilization
• Location data (with your permission)
• Network information and connection details
• Browser type and version, language preferences
• Time zone, crash logs, and error reports

D. Communication Data

• Customer support messages and chat transcripts
• Email correspondence
• Survey responses and feedback
• Marketing preferences and communication history

4. Children's Privacy

If you believe we may have information from a minor, please contact us at privacy@tumahela.com.

5. How We Collect Your Information

We collect information through various methods:

A. Direct Collection

• Account registration and verification processes
• Transaction initiation and completion
• Customer support interactions
• Survey participation and feedback submission
• Marketing opt-ins and communication preferences

B. Automatic Collection

• App usage and interaction data
• Device and technical information
• Location data (when enabled)
• Performance and error logs

C. Third-Party Sources

• Identity verification services and KYC providers
• Credit reference agencies and fraud prevention services
• Mobile network operators for phone verification
• Cryptocurrency blockchain networks
• Banking partners and payment processors
• Regulatory databases for compliance checks

6. How We Use Your Information

We use your personal information for the following purposes:

A. Service Provision

• Account creation, maintenance, and authentication
• Processing remittances and money transfers
• Facilitating cryptocurrency to fiat conversions
• Enabling mobile money transactions (M-Pesa, MTN, etc.)
• Processing bank deposits and withdrawals
• Merchant and bill payment processing
• Airtime top-up services

B. Security and Compliance

• Identity verification and KYC compliance
• Anti-money laundering (AML) monitoring
• Fraud detection and prevention
• Sanctions screening and regulatory compliance
• Transaction monitoring and risk assessment

C. Customer Support

• Responding to inquiries and resolving issues
• Providing technical assistance
• Processing complaints and feedback
• Account recovery and security assistance

D. Business Operations

• Service improvement and development
• Market research and analytics
• Performance monitoring and optimization
• Risk management and underwriting
• Legal compliance and regulatory reporting

E. Marketing and Communications

• Sending service updates and notifications
• Marketing communications (with consent)
• Promotional offers and product announcements
• Educational content about financial services

7. Legal Basis for Processing

We process your personal information based on:

A. Contract Performance

• Providing requested financial services
• Account management and maintenance
• Transaction processing and settlement

B. Legal Obligations

• KYC and AML compliance requirements
• Regulatory reporting obligations
• Tax reporting and documentation
• Court orders and legal processes

C. Legitimate Interests

• Fraud prevention and security measures
• Service improvement and development
• Marketing and business development
• Risk management and analytics

D. Consent

• Marketing communications
• Optional data collection (surveys, feedback)
• Biometric data processing
• Location tracking

8. Data Sharing and Disclosure

We may share your personal information with:

A. Service Providers and Partners

• Payment processors and banking partners
• Mobile money operators (Safaricom, MTN, Vodacom)
• Cryptocurrency exchanges and wallet providers
• Identity verification and KYC service providers
• Cloud storage and technology infrastructure providers
• Customer support and call center services
• Marketing and analytics platforms

B. Regulatory and Legal Authorities

• Financial intelligence units and regulatory bodies
• Law enforcement agencies (when legally required)
• Tax authorities and government agencies
• Courts and legal proceedings participants

C. Business Transfers

• Potential buyers in merger or acquisition scenarios
• Investors and financial partners
• Professional advisors (lawyers, accountants, auditors)

D. Affiliate Companies

• Tuma Hela group companies and subsidiaries
• Joint venture partners and strategic alliances

9. International Data Transfers

As a global financial services provider, we may transfer your personal information to countries outside your residence, including the United States, United Kingdom, European Union, Kenya, Nigeria, Ghana, Tanzania, Uganda, and other jurisdictions where we operate.

We ensure all international transfers comply with applicable data protection laws through:

• Standard Contractual Clauses (SCCs)
• Adequacy decisions by relevant authorities
• Binding Corporate Rules (BCRs)
• Other appropriate safeguards as required by law

10. Data Security

We implement comprehensive security measures to protect your personal information:

A. Technical Safeguards

• End-to-end encryption for sensitive data
• Secure Socket Layer (SSL) technology
• Multi-factor authentication systems
• Regular security audits and penetration testing
• Intrusion detection and prevention systems

B. Organizational Measures

• Employee training on data protection
• Access controls and need-to-know principles
• Regular security policy updates
• Incident response procedures
• Vendor security assessments

C. Physical Security

• Secure data centers with restricted access
• Environmental controls and monitoring
• Backup and disaster recovery systems

11. Data Retention

We retain your personal information for as long as necessary to:

• Provide our Services and maintain your account
• Comply with legal and regulatory obligations
• Resolve disputes and enforce agreements
• Prevent fraud and ensure security

Specific Retention Periods:

You may request account deletion at any time, subject to legal retention requirements.

12. Your Privacy Rights

Depending on your jurisdiction, you may have the following rights:

A. Access Rights

• Request copies of your personal information
• Obtain information about how we process your data
• Receive data in a portable format

B. Correction and Update Rights

• Correct inaccurate or incomplete information
• Update your personal details and preferences

C. Deletion Rights

• Request deletion of your personal information
• Right to be forgotten (subject to legal exceptions)

D. Restriction and Objection Rights

• Limit how we process your information
• Object to processing based on legitimate interests
• Opt-out of marketing communications

E. Consent Withdrawal

• Withdraw consent for optional processing
• Change marketing preferences
• Disable location tracking

13. Cryptocurrency-Specific Privacy Considerations

For cryptocurrency-related services:

A. Blockchain Transparency

• Cryptocurrency transactions are recorded on public blockchains
• Transaction details may be permanently visible
• We cannot delete blockchain transaction records

B. Wallet Integration

• We may access wallet addresses you provide
• Transaction history from connected wallets may be analyzed
• Private keys are never stored or accessed by us

C. Conversion Services

• Exchange rate data and conversion history are retained
• Third-party exchange partners may have separate privacy policies
• Cross-border crypto transfers may involve multiple jurisdictions

14. Marketing and Communications

We may send you marketing communications about:

• New features and service updates
• Promotional offers and discounts
• Educational content about financial services
• Market insights and exchange rate alerts

You can opt-out of marketing communications at any time by:

• Using unsubscribe links in emails
• Updating preferences in your account settings
• Contacting customer support
• Emailing privacy@tumahela.com

15. Cookies and Tracking Technologies

Our App and website use cookies and similar technologies to:

• Remember your preferences and settings
• Analyze usage patterns and improve services
• Provide personalized content and recommendations
• Measure marketing campaign effectiveness

You can control cookie settings through your device or browser preferences.

16. Third-Party Links and Services

Our Services may contain links to third-party websites, apps, or services. This Privacy Policy does not apply to third-party services. We encourage you to review the privacy policies of any third-party services you access through our platform.

17. Updates to This Privacy Policy

We may update this Privacy Policy periodically to reflect changes in our practices, services, or legal requirements. We will notify you of material changes through:

• In-app notifications
• Email communications
• Website announcements
• Push notifications

The "Last Updated" date at the top indicates when changes were made.

18. Jurisdiction-Specific Provisions

A. European Union Residents (GDPR)

• Legal basis for processing as outlined in Article 6 GDPR
• Right to lodge complaints with supervisory authorities
• Data Protection Officer contact: dpo@tumahela.com

B. California Residents (CCPA/CPRA)

• Right to know categories of information collected
• Right to delete personal information
• Right to opt-out of sale (we do not sell personal information)
• Non-discrimination for exercising rights

C. Canadian Residents (PIPEDA)

• Consent requirements for collection and use
• Right to access and correct personal information
• Privacy Officer contact: privacy@tumahela.com

19. Contact Information

For privacy-related questions, concerns, or requests:

If you believe we have not addressed your privacy concerns adequately, you may file a complaint with your local data protection authority.