Privacy Policy

1. Information We Collect

1.1 Information you provide

TENA may collect information that Users voluntarily provide, including:

• full names;
• usernames;
• phone numbers;
• email addresses;
• national identification details;
• profile photos or selfies;
• payment information;
• delivery addresses;
• communications through the Platform;
• item listings, photos, videos, and descriptions;
• Buyer requests / wanted items;
• customer support inquiries.

2. Automatically Collected Information

TENA may automatically collect certain technical and usage information, including:

• IP address;
• device information;
• browser type;
• operating system;
• location information;
• login activity;
• Platform interactions;
• transaction history;
• cookies and similar technologies.

3. How We Use Information

TENA may use collected information to:

• create and manage user accounts;
• facilitate transactions and payments;
• process deliveries;
• verify identity and prevent fraud;
• improve platform security and performance;
• communicate with users;
• provide customer support;
• enforce terms and policies;
• comply with legal and regulatory obligations;
• investigate suspicious or unlawful activities;
• personalize User experience;
• recommend relevant listings or Buyer Requests.

4. Payment Information

4.1 Payments made through TENA may be processed by licensed third-party payment service providers and financial institutions.

4.2 TENA may temporarily hold transaction funds for operational, fraud prevention, verification, dispute management, or transaction completion purposes.

4.3 TENA does not store full card or sensitive banking credentials unless expressly permitted by applicable law and secure payment standards.

5. Identity Verification & Security

5.1 TENA may require users to complete identity verification procedures, including:

• national ID verification;
• selfie verification;
• phone number verification;
• email verification;
• IMEI or ownership verification for relevant items.

5.2 TENA may use automated systems, moderation tools, or manual reviews to detect fraud, suspicious activity, prohibited items, or policy violations.

6. Communications & Platform Monitoring

6.1 Communications conducted through the Platform may be monitored, reviewed, filtered, or retained for:

• fraud prevention;
• security;
• dispute resolution;
• policy enforcement;
• compliance with applicable law.

6.2 Users are prohibited from sharing external contact details for the purpose of bypassing the platform.

7. Sharing of Information

TENA may share information with:

• payment service providers;
• delivery / logistics partners;
• identity verification providers;
• customer support providers;
• legal or regulatory authorities;
• courts, law enforcement, or government agencies where legally required;
• affiliated companies or service providers assisting in Platform operations.

TENA does not sell users' personal data to third parties.

8. Delivery Services

Where delivery services are used, TENA may share limited necessary information with logistics or delivery partners, including:

• recipient name;
• phone number;
• delivery address;
• transaction reference information.

9. Cookies & Tracking Technologies

TENA may use cookies and similar technologies to:

• improve functionality;
• remember preferences;
• analyze traffic;
• improve security;
• personalize User experience.

Users may disable cookies through browser settings, although some Platform features may not function properly.

10. Data Retention

TENA may retain information:

• for as long as necessary to provide services;
• to comply with legal obligations;
• for fraud prevention and dispute resolution;
• for legitimate business and operational purposes.

Certain information may continue to be retained after account closure where legally required or reasonably necessary.

11. User Rights

Subject to applicable law, Users may request:

• access to their personal data;
• correction of inaccurate information;
• deletion of certain information;
• restriction of processing;
• withdrawal of consent where applicable.

TENA may refuse requests where retention is required by law, security obligations, fraud prevention needs, or legitimate business interests.

12. Security

TENA implements reasonable technical, administrative, and organizational security measures intended to protect User information against:

• unauthorized access;
• misuse;
• loss;
• disclosure;
• alteration;
• destruction.

However, no system can be guaranteed completely secure, and Users acknowledge the inherent risks associated with online platforms and electronic communications.

13. Prohibited Content & Public Order

TENA prohibits the use of the Platform for:

• illegal activities;
• fraudulent conduct;
• sale of prohibited items;
• hate speech;
• discrimination;
• genocide ideology;
• divisionism;
• violence;
• or any conduct contrary to Rwandan law, public order, national unity, and reconciliation values.

TENA reserves the right to remove content, suspend accounts, and cooperate with competent authorities where necessary.

14. Children

TENA is not intended for use by persons below the minimum legal age required under applicable law without parental or legal guardian supervision.

15. International Transfers

User information may be processed, stored, or transferred within Rwanda or in other jurisdictions where TENA or its service providers operate, subject to applicable safeguards and legal requirements.

16. Changes to This Privacy Policy

TENA may update or modify this Privacy Policy at any time. Updated versions become effective upon publication on the Platform.

Continued use of the Platform after updates constitutes acceptance of the revised Privacy Policy.

17. Contact

For questions, concerns, or privacy-related requests, Users may contact:

TENA, Kigali, Rwanda