🔒 Privacy Policy

1. Information We Collect

We may collect the following types of information:

• Personal Identification Information: Full name, date of birth, National ID number
• Phone Numbers and Contact Details: Your WhatsApp number and other contact information
• Transaction Records: Payment history, amounts, recipients, and timestamps
• Device and Usage Data: Device type, operating system, IP address, and usage patterns
• National ID Card: Photo of your government-issued identification for verification

2. Purpose of Data Collection

Data is collected to:

• Verify User Identity (KYC): Comply with Know Your Customer regulations
• Process Transactions: Enable money transfers, payments, and cash-outs
• Prevent Fraud and Financial Crime: Detect and prevent money laundering, fraud, and other illegal activities
• Meet Regulatory Obligations: Comply with laws and regulations of Sierra Leone
• Improve Service Delivery: Enhance user experience and service quality
• Customer Support: Respond to your inquiries and resolve issues

3. Data Sharing

Information may be shared with:

• Authorized Agents and Merchants: To facilitate cash-in, cash-out, and payment services
• Banking and Financial Partners: To process transactions and maintain account balances
• Regulatory Bodies: Such as the Bank of Sierra Leone, as required by law
• Law Enforcement Agencies: When legally required or to prevent fraud and crime
• Service Providers: Third-party vendors who help us operate our service (e.g., hosting, database management)

4. Data Security

JayPay uses reasonable technical and organizational measures to protect your data, including:

• Encryption: All sensitive data is encrypted in transit and at rest
• Access Controls: Limited access to personal data on a need-to-know basis
• Secure Infrastructure: Protected servers and databases
• Regular Audits: Security reviews and vulnerability assessments
• PIN Protection: Your PIN is hashed using industry-standard encryption

5. Data Retention

Data is retained only as long as necessary to:

• Comply with Legal and Regulatory Obligations: As required by Sierra Leone law
• Resolve Disputes: To address complaints and legal claims
• Maintain Operational Integrity: To ensure service continuity and security
• Prevent Fraud: To detect patterns of fraudulent activity

Transaction records are typically retained for a minimum of 7 years as required by financial regulations.

6. User Rights

You have the right to:

• Access Your Personal Data: Request a copy of the information we hold about you
• Correction of Inaccurate Data: Request correction of incorrect or incomplete information
• Deletion: Request deletion of your data where legally permissible
• Object to Processing: Object to certain types of data processing
• Data Portability: Request transfer of your data to another service provider

To exercise these rights, contact us at support@jaypay.sl

7. Cookies and Tracking

JayPay operates primarily through WhatsApp and does not use traditional web cookies. However:

• Our admin dashboard may use essential cookies for authentication and security
• We may collect device information and usage patterns
• WhatsApp's own privacy policy applies to messages sent through their platform

8. Children's Privacy

JayPay is not intended for use by individuals under the age of 18. We do not knowingly collect personal information from minors.

9. Changes to Privacy Policy

This policy may be updated periodically to reflect changes in:

• Our services and practices
• Legal and regulatory requirements
• Technology and security measures

Continued use of JayPay after changes are posted constitutes acceptance of the updated Privacy Policy.

10. International Data Transfers

Your data is primarily stored and processed in Sierra Leone. If data is transferred internationally, we ensure adequate protection in accordance with applicable laws.