Afghan Pay Privacy Policy
Protecting your data across Afghanistan
Contents
Scope
This Policy applies to Afghan Pay's platform and services used by our Master Distributors, Distributors, Resellers, and Retailers to recharge Customers via USSD, SMPP, and Online (mobile/web).
Roles & Definitions
Customer
An end user who only receives a top-up (recharge); no platform account.
Retailer
Sells/top-ups Customers; receives stock/credit from a Reseller/Distributor/Master Distributor.
Reseller
Can create Retailers and transfer stock/credit to them.
Distributor
Can create Resellers and Retailers and transfer stock/credit to them.
Master Distributor
Can create multiple Distributors, Resellers, and Retailers; receives stock/credit from Afghan Pay (admin) and redistributes downline.
Admin (Afghan Pay)
Can create any role and allocate stock/credit.
Channels
USSD, SMPP, Online (mobile or web) recharge.
Data Controller
Afghan Pay is the data controller for personal data processed in our platform (accounts, access, and recharge logs).
Mobile Network Operators (MNOs) act as independent controllers for network-side processing required to complete the recharge.
Master Distributors/Distributors/Resellers/Retailers are users of the Afghan Pay system. If they independently collect data outside Afghan Pay (e.g., their own customer lists), they act as controllers for that separate data.
Data We Collect
We practice data minimization and only collect what's necessary
Account data (for Master Distributor/Distributor/Reseller/Retailer): business name, contact person, phone number, email, role, credentials, and status.
Recharge logs: target MSISDN, operator, amount, time/date, status, channel (USSD/SMPP/Online), and reference IDs.
Access logs: user ID/role, actions (create/transfer stock, create users), timestamps, and IP (for security/audit).
No card/bank/wallet data — all balances are prepaid (cash-based).
Use & Disclosure
We use data strictly to operate accounts, manage stock/credit, and process top-ups.
We share only what is necessary with MNOs to complete the recharge (target MSISDN, amount, and required technical metadata).
We do not share with banks/wallets (prepaid model) and do not sell personal data.
Retention
Recharge & Access Logs
Retained for 7 years for audit and compliance, then anonymized or securely deleted.
Account Records
Kept while the account is active and up to 2 years after closure (for reconciliation and dispute history).
Your Rights
Simple and transparent rights for our platform users
Access Only
Platform users (Master Distributor/Distributor/Reseller/Retailer) may request access to their personal data and activity logs.
Logs are immutable operational records required for audit and service integrity.
Limitations
Onboarding & Access
Prospects apply to join; after approval, Admin creates the user in Afghan Pay and issues a one-time password (OTP) with credentials.
Users sign in via web or mobile, change the OTP on first login, and operate within their role permissions.
Recharging Customers is performed through USSD, SMPP, or Online channels.
User Responsibilities
Use Afghan Pay solely for authorized top-up operations.
Keep credentials confidential; do not share accounts; change the OTP on first login.
Collect only what is necessary to complete a recharge; do not store extra Customer data outside the system unless required for your own lawful purposes.
Transfer stock/credit only to downline you created and are authorized to manage.
Preserve logs and cooperate in audits or misuse investigations.
Immediately report suspected abuse or unauthorized access through your admin chain.
Changes to This Policy
We may update this Policy as needed. The 'Effective date' indicates the latest version. Continued use of the platform after updates means you accept the changes.