Privacy Policy

1. Introduction

PeroyaalPay ("we," "our," or "us") is committed to protecting your privacy and personal information. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you use our mobile application, website, and related services (collectively, the "Service").

By using our Service, you consent to the data practices described in this Privacy Policy. If you do not agree with the terms of this Privacy Policy, please do not use our Service.

2. Information We Collect

2.1 Personal Information

We collect the following personal information when you create an account:

• Identity Information: First name, last name, email address
• Contact Information: Phone number, physical address
• Account Credentials: Password (encrypted), transaction PIN
• Financial Information: Bank account details, wallet addresses
• Verification Documents: Government-issued ID, proof of address

2.2 Transaction Information

We collect detailed information about your transactions, including:

• Transaction type (buy, sell, transfer, exchange)
• Transaction amounts and currencies
• Transaction reference numbers
• Transaction status and timestamps
• Proof of payment documents
• Recipient and sender information

2.3 Cryptocurrency Information

For cryptocurrency services, we collect:

• Cryptocurrency wallet addresses
• Transaction hashes and block confirmations
• Network information (Bitcoin, Ethereum, etc.)
• Exchange rates and market data

2.4 Technical Information

We automatically collect certain technical information:

• Device information (model, operating system, unique identifiers)
• IP address and location data
• App usage patterns and preferences
• Log files and error reports
• Cookies and similar tracking technologies

2.5 Referral Information

We collect information related to our referral program:

• Referral codes and relationships
• Referral bonus amounts and withdrawals
• Referral activity and success rates

3. How We Use Your Information

We use your information for the following purposes:

3.1 Service Provision

• Process and execute your transactions
• Provide cryptocurrency trading services
• Manage your digital wallet
• Facilitate money transfers and bill payments
• Calculate and distribute referral bonuses

3.2 Account Management

• Create and maintain your account
• Verify your identity and prevent fraud
• Provide customer support
• Send important account notifications

3.3 Security and Compliance

• Detect and prevent fraud, money laundering, and other illegal activities
• Comply with anti-money laundering (AML) and know-your-customer (KYC) regulations
• Monitor transactions for suspicious activity
• Maintain security of our systems and services

3.4 Communication

• Send transaction confirmations and receipts
• Provide customer support and respond to inquiries
• Send important service updates and security alerts
• Share promotional offers and new feature announcements (with your consent)

3.5 Analytics and Improvement

• Analyze usage patterns to improve our services
• Develop new features and functionality
• Conduct research and analytics
• Optimize user experience and app performance

4. Information Sharing and Disclosure

We do not sell, trade, or rent your personal information to third parties. We may share your information in the following circumstances:

4.1 Service Providers

We share information with trusted third-party service providers who assist us in:

• Payment processing (Flutterwave, banks, payment gateways)
• Identity verification and KYC services
• Cryptocurrency exchange and wallet services
• Cloud storage and data hosting
• Customer support and communication
• Analytics and security monitoring

4.2 Legal Requirements

We may disclose your information when required by law or to:

• Comply with legal obligations and court orders
• Respond to government requests and investigations
• Protect our rights, property, and safety
• Prevent fraud and illegal activities
• Enforce our Terms of Service

4.3 Business Transfers

In the event of a merger, acquisition, or sale of assets, your information may be transferred to the new entity, subject to the same privacy protections.

5. Data Security

We implement comprehensive security measures to protect your information:

5.1 Technical Safeguards

• End-to-end encryption for sensitive data transmission
• Advanced encryption algorithms (AES-256) for data storage
• Secure socket layer (SSL) certificates for web communications
• Multi-factor authentication for admin access
• Regular security audits and penetration testing
• Intrusion detection and prevention systems

5.2 Administrative Safeguards

• Strict access controls and role-based permissions
• Regular employee security training
• Background checks for employees with data access
• Incident response procedures
• Data retention and disposal policies

5.3 Physical Safeguards

• Secure data centers with 24/7 monitoring
• Biometric access controls
• Fire suppression and environmental controls
• Redundant backup systems

6. Data Retention

We retain your information for as long as necessary to provide our services and comply with legal obligations:

• Account Information: Retained while your account is active and for 7 years after closure
• Transaction Records: Retained for 7 years for regulatory compliance
• Identity Verification: Retained for 5 years after account closure
• Communication Records: Retained for 3 years
• Technical Logs: Retained for 1 year

After the retention period, we securely delete or anonymize your information unless longer retention is required by law.

7. Your Rights and Choices

You have the following rights regarding your personal information:

7.1 Access and Portability

• Request access to your personal information
• Receive a copy of your data in a portable format
• View your transaction history and account details

7.2 Correction and Updates

• Update your personal information in your account settings
• Request correction of inaccurate information
• Modify your communication preferences

7.3 Deletion and Restriction

• Request deletion of your account and associated data
• Request restriction of certain data processing activities
• Withdraw consent for marketing communications

7.4 Objection and Opt-out

• Object to certain types of data processing
• Opt-out of marketing communications
• Disable location tracking and analytics

To exercise these rights, please contact us using the information provided in the Contact section. We will respond to your request within 30 days.

8. International Data Transfers

Your information may be transferred to and processed in countries other than your country of residence. We ensure appropriate safeguards are in place:

• Standard contractual clauses for data transfers
• Adequacy decisions by relevant data protection authorities
• Certification under recognized privacy frameworks
• Binding corporate rules for intra-group transfers

9. Children's Privacy

Our Service is not intended for children under 18 years of age. We do not knowingly collect personal information from children under 18. If we become aware that we have collected personal information from a child under 18, we will take steps to delete such information immediately.

10. Cookies and Tracking Technologies

We use cookies and similar technologies to enhance your experience:

10.1 Types of Cookies

• Essential Cookies: Required for basic functionality and security
• Performance Cookies: Help us understand how you use our Service
• Functional Cookies: Remember your preferences and settings
• Marketing Cookies: Used for targeted advertising (with your consent)

10.2 Managing Cookies

You can control cookies through your browser settings. However, disabling certain cookies may affect the functionality of our Service.

11. Third-Party Services

Our Service may contain links to third-party websites or integrate with third-party services. We are not responsible for the privacy practices of these third parties. We encourage you to review their privacy policies.

Key third-party services we use include:

• Flutterwave for payment processing
• Cloud hosting providers for data storage
• Analytics services for app performance monitoring
• Customer support platforms

12. Changes to Privacy Policy

We may update this Privacy Policy from time to time. We will notify you of any material changes by:

• Posting the updated policy on our website
• Sending email notifications to registered users
• Displaying in-app notifications
• Updating the "Last updated" date at the top of this policy

Your continued use of our Service after changes constitutes acceptance of the updated Privacy Policy.

13. Contact Information

If you have any questions about this Privacy Policy or our data practices, please contact us:

14. Regulatory Compliance

We comply with applicable data protection laws and regulations, including:

• Nigeria Data Protection Regulation (NDPR)
• General Data Protection Regulation (GDPR) for EU users
• California Consumer Privacy Act (CCPA) for California residents
• Anti-Money Laundering (AML) and Know Your Customer (KYC) requirements