Privacy Policy

Last Updated: March 6, 2025

1. Introduction

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

Please read this Privacy Policy carefully. By accessing or using our Services, you acknowledge that you have read, understood, and agree to be bound by this Privacy Policy. If you do not agree with our policies and practices, please do not use our Services.

2. Information We Collect

We collect several types of information from and about users of our Services:

Personal Information

Personal information is information that identifies you as an individual. The personal information we collect may include:

• Contact Information: Name, email address, phone number, and mailing address
• Identity Verification Information: Date of birth, national identification numbers, passport information, and photographs of government-issued identification
• Financial Information: Bank account details, mobile money account information, payment card details, and cryptocurrency wallet addresses
• Transaction Information: Records of payments, transfers, and other transactions made through our Services
• Business Information: Business name, business address, business type, and ownership information (for business accounts)

Non-Personal Information

We also collect non-personal information that does not directly identify you but is related to your use of our Services:

• Device Information: IP address, device type, operating system, browser type, mobile network information, and device identifiers
• Usage Information: Information about how you use our Services, including log data, clickstream data, and the pages you visit
• Location Information: General location information based on your IP address or more precise location if you grant permission
• Cookies and Similar Technologies: Information collected through cookies, web beacons, and similar technologies

Information Type	Purpose	Legal Basis
Contact Information	Account creation, customer service, communications	Contract performance, Legitimate interests
Identity Verification Information	Compliance with regulations, fraud prevention	Legal obligation, Contract performance
Financial Information	Processing transactions, fraud prevention	Contract performance, Legitimate interests
Transaction Information	Processing transactions, record-keeping, analytics	Contract performance, Legal obligation
Device Information	Service improvement, security, analytics	Legitimate interests

3. How We Use Your Information

We use the information we collect for various purposes, including:

• Providing Our Services: To process transactions, maintain your account, and provide customer support
• Improving Our Services: To understand how users interact with our Services and to enhance user experience
• Compliance: To comply with legal and regulatory requirements, including anti-money laundering (AML) and know-your-customer (KYC) obligations
• Security: To protect our Services and users from fraud, unauthorized access, and other security threats
• Communications: To send you service announcements, updates, security alerts, and support messages
• Marketing: With your consent, to provide you with information about our products, services, and promotions
• Analytics: To analyze usage patterns, trends, and preferences to improve our Services

4. Information Sharing and Disclosure

We may share your information with third parties in the following circumstances:

• Service Providers: We may share information with third-party vendors, consultants, and service providers who perform services on our behalf, such as payment processors, cloud hosting providers, and customer support services.
• Business Partners: We may share information with business partners, such as financial institutions and mobile money providers, to facilitate transactions and provide the Services.
• Legal Requirements: We may disclose information if required to do so by law or in response to valid requests by public authorities (e.g., a court or government agency).
• Business Transfers: If we are involved in a merger, acquisition, or sale of all or a portion of our assets, your information may be transferred as part of that transaction.
• Protection of Rights: We may disclose information to protect and defend the rights, property, or safety of DoronPay, our users, or others.
• With Your Consent: We may share information with third parties when you have given us your consent to do so.

5. Data Security

We implement appropriate technical and organizational measures to protect the security of your personal information. However, please be aware that no method of transmission over the Internet or method of electronic storage is 100% secure.

Our security measures include:

• Encryption of sensitive information in transit and at rest
• Access controls to limit who can access your information
• Regular security assessments and audits
• Employee training on security and privacy practices
• Physical security measures at our facilities

While we strive to use commercially acceptable means to protect your personal information, we cannot guarantee its absolute security. You are responsible for maintaining the confidentiality of your account credentials and for restricting access to your devices.

6. Data Retention

We retain your information for as long as necessary to provide the Services you have requested, or for other essential purposes such as complying with legal obligations, resolving disputes, and enforcing our agreements.

The criteria used to determine our retention periods include:

• The length of time we have an ongoing relationship with you
• Whether there is a legal obligation to which we are subject
• Whether retention is advisable in light of our legal position (e.g., in connection with statutes of limitations, litigation, or regulatory investigations)

7. Your Rights and Choices

Depending on your location, you may have certain rights regarding your personal information. These may include:

• Access: You may request access to the personal information we hold about you.
• Correction: You may request that we correct inaccurate or incomplete information.
• Deletion: You may request that we delete your personal information in certain circumstances.
• Restriction: You may request that we restrict the processing of your information in certain circumstances.
• Data Portability: You may request a copy of your personal information in a structured, commonly used, and machine-readable format.
• Objection: You may object to the processing of your personal information in certain circumstances.
• Withdrawal of Consent: You may withdraw your consent at any time if we rely on consent to process your information.

To exercise any of these rights, please contact us using the information provided in the "Contact Us" section. We will respond to your request within the timeframe required by applicable law.

8. International Data Transfers

DoronPay is based in Ghana, and your information may be transferred to, stored, and processed in Ghana and other countries where our service providers are located. These countries may have data protection laws that differ from those in your country of residence.

If we transfer your information to other countries, we will take appropriate safeguards to ensure that your information receives an adequate level of protection in the jurisdictions in which we process it.

9. Children's Privacy

Our Services are not intended for children under the age of 18. We do not knowingly collect personal information from children under 18. If you believe we have collected information from a child under 18, please contact us immediately, and we will take steps to delete such information.

10. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. The date of the most recent revision will be indicated at the top of the page. We encourage you to review this Privacy Policy periodically to stay informed about how we are protecting your information.

If we make material changes to this Privacy Policy, we will notify you through a notice on our website or by email before the changes become effective.

11. Contact Us

If you have any questions, concerns, or requests regarding this Privacy Policy or our privacy practices, please contact us at:

Email: privacy@doronpay.com
Phone: +233 50 123 4567
Address: 123 Independence Avenue, Accra, Ghana

For data protection inquiries, you can contact our Data Protection Officer at dpo@doronpay.com.