Table of Contents

  1. Overview
  2. Data Controller & Processor Roles
  3. Legal Bases for Processing
  4. Your Rights Under GDPR
  5. Sources of Personal Data
  6. Categories of Personal Data
  7. Purposes of Processing
  8. Recipients of Personal Data
  9. International Data Transfers
  10. Data Retention
  11. Security Measures
  12. Data Protection Officer
  13. Children's Data
  14. Filing Complaints
  15. Submit a GDPR Request

1. Overview

The General Data Protection Regulation (GDPR) is the European Union's comprehensive data protection law. It gives individuals in the EU and EEA (and the UK under the UK GDPR) greater control over their personal data and imposes obligations on organizations that process their data.

PamojaMeet is committed to complying with the GDPR and supporting our users in exercising their rights. This page provides specific information about our GDPR compliance and how you can exercise your rights.

Who does this page apply to? This GDPR page applies to all users who are in the European Union, European Economic Area, or United Kingdom. If you are located in another jurisdiction, please refer to our Privacy Policy for information about the data protection laws that apply to you.

2. Data Controller & Processor Roles

2.1 Data Controller

PamojaMeet acts as the Data Controller for the following processing activities:

2.2 Data Processor

PamojaMeet acts as a Data Processor when processing personal data on behalf of healthcare providers using our telemedicine features. In these cases:

2.3 Joint Controllers

For certain processing activities (e.g., meeting recordings shared between participants), PamojaMeet and meeting hosts may be Joint Controllers. We have agreements in place to ensure GDPR compliance for joint processing activities.

We process personal data under the following legal bases as defined in Article 6 of the GDPR:

Legal BasisGDPR ArticleProcessing Activities
Consent Art. 6(1)(a) Marketing emails, non-essential cookies, AI features, data sharing with third parties for advertising
Contract Performance Art. 6(1)(b) Providing the Service, processing payments, managing subscriptions, delivering support
Legal Obligation Art. 6(1)(c) Tax record retention, responding to lawful requests from authorities, compliance with court orders
Legitimate Interests Art. 6(1)(f) Security monitoring, fraud prevention, analytics, service improvement, internal administrative purposes
Vital Interests Art. 6(1)(d) Emergency situations in telemedicine contexts
Substantial Public Interest Art. 9(2)(g) Public health purposes (where applicable in telemedicine contexts)
Health Data (Explicit Consent) Art. 9(2)(a) Processing of health data for telemedicine services (with explicit consent of the data subject)

Legitimate Interests Assessment: When we rely on legitimate interests, we conduct a Legitimate Interests Assessment (LIA) to balance our interests against your rights and freedoms. You can request a copy of our LIAs by contacting our DPO.

4. Your Rights Under GDPR

As a data subject under the GDPR, you have the following rights:

RightGDPR ArticleDescriptionHow to Exercise
Right of Access Art. 15 Obtain confirmation of whether we process your data and receive a copy of your data Request via form below or email
Right to Rectification Art. 16 Have inaccurate personal data corrected or incomplete data completed Account settings or request via form below
Right to Erasure Art. 17 Have your personal data deleted ("right to be forgotten") Request via form below or email
Right to Restriction Art. 18 Restrict processing of your personal data in certain circumstances Request via form below or email
Right to Data Portability Art. 20 Receive your data in a structured, commonly used, machine-readable format Request via form below or email
Right to Object Art. 21 Object to processing based on legitimate interests or for direct marketing Request via form below or email
Right re: Automated Decisions Art. 22 Not be subject to decisions based solely on automated processing, including profiling Request via form below or email
Right to Withdraw Consent Art. 7(3) Withdraw consent at any time (without affecting prior lawful processing) Account settings or contact us

Exercising Your Rights: We will respond to all GDPR requests within 30 days. If we need more time (up to 60 additional days for complex requests), we will notify you within the initial 30-day period. There is no charge for most requests, but we may charge a reasonable fee for manifestly unfounded or excessive requests.

5. Sources of Personal Data

We collect personal data from the following sources:

6. Categories of Personal Data

We process the following categories of personal data:

CategoryExamplesSpecial Category?
Identity DataName, username, profile photoNo
Contact DataEmail address, phone numberNo
Account DataPassword (hashed), account preferencesNo
Financial DataPayment card details (tokenized), billing addressNo
Technical DataIP address, device info, browser type, operating systemNo
Usage DataFeatures used, meeting history, interaction patternsNo
Meeting ContentAudio, video, chat messages, screen shares, recordingsMay be (if health data)
Communication DataSupport tickets, feedback, survey responsesNo
Health DataTelemedicine session data, clinical notesYes (Art. 9)
Location DataApproximate location based on IP addressNo

7. Purposes of Processing

We process personal data for the following purposes:

PurposeLegal BasisData Categories
Providing the video conferencing serviceContractAll categories (as needed)
Account management and authenticationContractIdentity, Contact, Account
Payment processingContractFinancial, Identity, Contact
Customer supportContract / Legitimate interestIdentity, Contact, Communication
Service improvement and analyticsLegitimate interestTechnical, Usage
Security and fraud preventionLegitimate interestTechnical, Usage, Identity
Marketing communicationsConsentIdentity, Contact
AI-powered featuresConsentMeeting Content
Telemedicine servicesConsent / Vital interestsHealth Data, Meeting Content
Legal complianceLegal obligationAs required by law
Research and developmentLegitimate interestAggregated/anonymized data only

8. Recipients of Personal Data

We share personal data with the following categories of recipients:

All processors are bound by Data Processing Agreements (DPAs) that ensure GDPR-compliant processing.

9. International Data Transfers

PamojaMeet is based in Tanzania. When we transfer personal data from the EU/EEA/UK to countries outside these regions, we ensure appropriate safeguards are in place:

9.1 Transfer Mechanisms

MechanismWhen Applied
EU Standard Contractual Clauses (SCCs)Transfers to processors in non-adequate countries
UK International Data Transfer Agreement (IDTA)Transfers from the UK to non-adequate countries
Adequacy DecisionsTransfers to countries with an adequacy decision from the European Commission
Transfer Impact AssessmentsConducted for all international transfers to assess supplementary measures

9.2 Data Locations

Your data may be processed in the following locations:

You may request information about the specific safeguards applied to transfers to any particular country by contacting our DPO.

10. Data Retention

We retain personal data only as long as necessary for the purposes for which it was collected:

Data TypeRetention PeriodJustification
Account DataDuration of account + 30 daysContract performance
Meeting RecordingsPer plan limits (30-90 days)Contract / User request
Chat MessagesMeeting duration + 30 daysContract performance
Payment Records7 yearsLegal obligation (tax laws)
Usage Analytics26 months (anonymized after 12 months)Legitimate interest
Support Tickets3 years after resolutionLegitimate interest
Consent RecordsDuration of processing + 5 yearsLegal obligation (accountability)
Server Logs90 daysSecurity / Legitimate interest

11. Security Measures

We implement the following technical and organizational measures to protect personal data (as required by Article 32 of the GDPR):

11.1 Technical Measures

11.2 Organizational Measures

11.3 Breach Notification

In the event of a personal data breach:

12. Data Protection Officer

PamojaMeet has appointed a Data Protection Officer (DPO) who oversees our compliance with GDPR and other data protection laws.

You can contact our DPO at:

The DPO is responsible for:

13. Children's Data

The Service is not intended for children under 16 years of age (or the applicable age of digital consent in your jurisdiction, which may be as low as 13 in some EU member states).

If we become aware that we have collected personal data from a child without appropriate parental consent, we will delete the data promptly.

For telemedicine services involving minors, the healthcare provider (Data Controller) is responsible for obtaining appropriate parental/guardian consent.

14. Filing Complaints

If you believe that our processing of your personal data violates the GDPR, you have the right to lodge a complaint with a supervisory authority.

You can:

15. Submit a GDPR Request

Use this form to exercise any of your GDPR rights. We will respond within 30 days.

GDPR Rights Request

Verification: To protect your privacy, we may need to verify your identity before processing your request. We may ask you to provide additional information or confirm details about your account. We will not discriminate against you for exercising your GDPR rights.

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