1. Introduction

Pango is a product of ACHATE BDM ("ACHATE BDM," "we," "us," or "our"), a company registered in Rwanda (TIN: 156785393). This Privacy Policy explains how we collect, use, share, and protect information when you use the Pango mobile application and website (together, the "Service"). By using the Service, you agree to the collection and use of information as described here.

Pango is a budgeting and financial wellness platform. It does not hold, transfer, or move your money — it helps you plan and track it. This Policy reflects Pango's current features; as we introduce new features, we will update this Policy to reflect them.

2. Information We Collect

• Account information: name, phone number and/or email address, language preference, and password (stored securely, never in plain text).
• Financial planning data you provide: income sources, budget categories, transaction entries, savings goals, sinking funds, debt balances, and related notes you enter manually.
• Family/Group plan data: if you join a Family or Group plan, we record your plan membership and which specific categories you've chosen to share. Shared budgets are visible to the other members of that plan; everything else you enter remains private to you.
• Subscription status: if you activate a Classic plan, we record your plan type (Personal, Family, or Group) and activation status. Payment is currently made directly to us via mobile money outside the app; we do not automatically process or store your mobile money transaction details.
• Device and usage data: app version, device type, general usage patterns, and crash/error logs, used to maintain and improve the Service.
• Website data: pages visited and general analytics for visitors to the Pango website, including use of the free tools and calculators.

3. How We Use Your Information

• To provide and operate the budgeting, savings, and debt-tracking features of the Service.
• To send you notifications you've opted into (e.g. bill due dates, budget alerts, sinking fund progress) — delivered in-app only.
• To activate and manage your Classic plan subscription.
• To improve the Service, including using de-identified data for product analytics.
• To communicate with you about your account or support requests.
• To send you marketing communications about Pango's products, features, and services. By using the Service, you consent to receiving these communications; you may unsubscribe or opt out at any time.
• To comply with legal obligations and protect the security of the Service.

4. Legal Basis for Processing

Where Rwanda's Law No. 058/2021 Relating to the Protection of Personal Data and Privacy applies, we process personal data on the following bases: your consent, performance of the agreement between you and us (providing the Service you signed up for), and our legitimate interests in operating and improving the Service, balanced against your rights.

Where processing relies on your consent — such as sharing a category within a Family or Group plan — you may withdraw or change that sharing at any time through the app's settings, without affecting the lawfulness of processing before withdrawal.

5. Data Sharing & Third Parties

• Family/Group plan members: only the specific categories you've chosen to share, visible only to the other members of your specific plan — nothing else.
• Service providers: hosting, analytics, and notification infrastructure providers, bound by confidentiality and data protection obligations.
• Legal requirements: if required by law, regulation, or valid legal process.

We do not sell your personal data to third parties.

6. Data Storage & Security

Your data is stored on servers located in Rwanda. We use industry-standard measures to protect your information, including encryption of data in transit and at rest, and access controls limiting who can view personal data internally. No system is completely secure, and we encourage you to use a strong, unique password and enable any available app-level lock (PIN/biometric).

If a data breach occurs that affects your personal information, we will notify you directly.

7. Data Retention

We retain your information for as long as your account is active, or as needed to provide the Service. If you delete your account, we will delete or anonymize your personal data within 90 days, except where retention is required by law.

8. Your Rights

• Access the personal data we hold about you.
• Correct inaccurate or incomplete data.
• Request deletion of your account and associated data.
• Withdraw consent for optional data sharing (e.g. Family/Group category sharing) at any time.
• Object to certain processing, subject to applicable law.

To exercise these rights, contact us using the details in Section 13.

9. Children's Privacy

The Service is intended for users aged 18 and older. We do not knowingly collect personal data from anyone under 18. If we learn that we have inadvertently collected such data, we will take steps to delete it.

10. Cookies & Website Analytics

The Pango website uses basic analytics to understand visitor traffic and improve content, including usage of free tools and calculators. This Policy will be updated with a full cookie notice before any non-essential tracking technologies are introduced.

11. Third-Party Links

Our website may contain links to external sites, such as app store listings. We are not responsible for the privacy practices or content of any external sites, and we encourage you to review the privacy policy of any third-party site you visit.

12. Changes to This Policy

We may update this Privacy Policy from time to time, including as new features (such as automatic mobile money syncing) are introduced. Material changes will be communicated through the app or website before they take effect. Continued use of the Service after changes take effect constitutes acceptance of the updated Policy.

13. Contact Us

Questions about this Privacy Policy or your data can be directed to: info@achatebdm.rw — ACHATE BDM, Kigali, Rwanda.