Privacy Policy

InversePay Africa Limited ("we" or "us" or "our") respects the privacy of our users ("user" or "you"). We'll be the controller of the information you provide to us.

This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you visit our mobile application (the "Application"). Please read this Privacy Policy carefully. Please note that we reserve the right to change this Privacy Policy anytime and for any reason. We will alert you about any changes via in Application notifications. You are encouraged to review this Privacy Policy periodically to stay informed of updates.

This Privacy Policy does not apply to the third-party online/mobile store from which you install the Application or make payments, including any in-game virtual items, which may also collect and use your data. We are not responsible for any of the data collected by any such third party.

This policy applies to all personal data processed by InversePay Africa in the course of providing financial services, including data collected through our digital platforms, API integrations, and other channels.

Effective Date: Upon Insurance.

A. Collection of Your Information

We may collect information about you in a variety of ways. The information we may collect via the Application depends on the service you use and includes:

I. Personal Data - Demographic and other personally identifiable information (such as your name and email address) that you voluntarily give to us when choosing to participate in various activities related to the Application, such as chat, posting messages in comment sections or in our forums, liking posts, sending feedback, and responding to surveys.

If you choose to share data about yourself via your profile, online chat, or other interactive areas of the Application, please be advised that all data you disclose in these areas is public and your data will be accessible to anyone who accesses the Application.

We may also collect information related to your national identification card number and require a self-portrait to verify your identity as per the requirements of Anti-Money Laundering and Counter-Terrorism Financing legislation.

That information along with other personally identifying information about you will be shared internally and may also be shared externally with our compliance, banking, aggregation and product offering partners that undertake an automated review of your information: (i) against relevant government-maintained sanctions lists and lists of politically exposed persons, (ii) for purposes of facial recognition against government provided identification documents, (iii) for accuracy against national databases, (iv) for confirming your identity against other relevant databases such as those maintained by companies providing credit reports, and (v) for the purpose of monitoring transactions for fraudulent and other illegal activities.

II. Derivative Data - The information our servers automatically collect when you access the Application, such as your native actions that are integral to the Application, as well as other interactions with the Application and other users via automatic audit server log.

III. Financial Data - Financial information, such as data related to your mobile money account and payment method, that we may collect when you purchase, order, return, exchange, or request information about our services from the Application.

Please note that we store only very limited if any, financial information that we collect in line with regulatory requirements for safeguarding such information. Otherwise, all financial information is stored by our payment processor.

IV. Mobile Device Access - We may request access or permission to certain features from your mobile device, including your mobile device's camera (for the purpose of "selfies" used for identification verification), contacts (for the purpose of engaging contacts to join you on the Application), SMS messages (which we may use in the future to simplify your login to the Application), storage (for storing your profile picture for the Application), and potentially GPS (for anti-fraud, Application security purposes) and other features.

If you wish to change our access or permissions, you may do so in your device's settings. It should be noted that like other Applications, we will have access to your device fingerprint which identifies the specific device used for the Application.

V. Mobile Device Data - Information such as your mobile device ID number, model, and manufacturer, version of your operating system, phone number, country, location, and any other data you choose to provide.

VI. Push Notifications - We may request to send you push notifications regarding your account or the Application. If you wish to opt out from receiving these types of communications, you may turn them off in the application under the settings tab.

VII. Third Party Data - Information from third parties, such as personal information or network friends, if you connect your account to the third party and grant the Application permission to access this information.

VIII. Data from Contests, Giveaways, and Surveys - Personal and other information you may provide when entering contests or giveaways and/or responding to surveys.

B. Use of Your Information

I. Legal Basis for Using Your Personal Information

Under data protection law, we can only use your personal information if we have a proper reason for doing so. In order to use your personal information, we rely on the following legal bases:

II. How We Use Your Information

Having accurate information about you permits us to provide you with a smooth, efficient, and customized experience. Specifically, we may use information collected about you via the Application to:

III. Automated Decision Making

We use an automated decision making system to determine whether a user has provided appropriate authentication to engage with the application, including verification of personally identifiable information ("PII").

This includes matching PII against national databases, publicly available information, sanctions lists, lists of politically exposed persons and other databases that provide information on potentially illegal activity; comparison by facial recognition of your selfie image against the image provided with your identification document or other database containing your image; and tracking your PII in the context of automated monitoring of transactions undertaken by you to look for potentially fraudulent or illegal activity.

In the event that we receive an automated report that there is a discrepancy, insufficiency or inaccuracy in the information provided by you, or an indication of potential fraudulent or illegal activity, our compliance and customer service teams will review the background information and may contact you by SMS or email for additional information or clarification.

If we are unable to continue with you as a user on our platform, we may provide you with the basis for the decision.

You have the right not to be subject to a decision based solely on automated processing, including profiling, which has legal consequences for you or similarly significant effects.

You have the right to object to an automated decision and ask that a person reviews it and/or to ask that we do not make our decision based on the automated score alone.

C. Disclosure of Your Information

We may share information we have collected about you in certain situations. At no time will our database of users ever be sold to any entity for the purpose of marketing or mailing lists.

Your information may be disclosed as follows:

I. By Law or To Protect Rights - If we believe the release of information about you is necessary to respond to legal process, investigate or remedy potential violations of our policies, or protect the rights, property, and safety of others, we may share your information as permitted or required by any applicable law, rule, or regulation.

II. Third-Party Service Providers - We may share your information with third parties that perform services for us or on our behalf, including payment processing, data analysis, email delivery, hosting services, customer service, and marketing assistance.

III. Marketing Communications - Where it is necessary for our legitimate business interests, we may use your personal data to promote our products or services to you. Where you have provided your consent, we may also share your information with third parties for marketing purposes, as permitted by law.

IV. Interactions with Other Users - If you interact with other users of the Application, those users may see your name, profile photo, and descriptions of your activity.

V. Third-Party Advertisers - We may use third-party advertising companies to serve ads when you visit the Application.

VI. Affiliates - We may share your information with our affiliates, including subsidiaries, joint venture partners or other companies under common control with us.

VII. Business Partners - With your consent, we may share your information with our business partners to offer certain products, services, or promotions.

VIII. Other Third Parties - We may share your information with advertisers and investors for the purpose of conducting general business analysis.

IX. Sale or Bankruptcy - If we reorganize or sell all or a portion of our assets, undergo a merger, are acquired by another entity, or enter bankruptcy, your information may be transferred to a successor entity.

D. Transferring Your Personal Information Out of the Rwanda

It is sometimes necessary for us to share your Personal Information outside Rwanda. These transfers are subject to special rules under Rwanda's data protection law.

Not all countries have the same data protection laws as Rwanda. We will, however, ensure the transfer complies with data protection laws and all personal information will be secure.

Under data protection law, it is also necessary to make these safeguards available to data subjects if they request.

If you would like further information please contact us (see 'Contact Us' below).

E. Security of Your Information

We use administrative, technical, and physical security measures to help protect your personal information.

While we have taken reasonable steps to secure the personal information you provide, please be aware that despite our efforts, no security measures are perfect or impenetrable, and no method of data transmission can be guaranteed against any interception or other type of misuse.

Any information disclosed online is vulnerable to interception and misuse by unauthorized parties. Therefore, we cannot guarantee complete security if you provide personal information.

Policy for Children

If you no longer wish to receive correspondence, emails, or other communications from us, you may opt out by noting your preferences at the time you register your account with the Application, logging into your account settings and updating your preferences, or contacting us using the contact information provided below.

If you no longer wish to receive correspondence, emails, or other communications from third parties, you are responsible for contacting the third party directly.

G. Your Rights

Under data protection law, you have a number of rights when it comes to your personal data:

H. How Long Will We Keep Your Personal Information

We will keep your personal information while we are providing products and services to you. Thereafter, we will keep your personal information for as long as is necessary to respond to questions, complaints or claims, to show that we treated you fairly, and to keep records required by law.

We will not retain your personal information for longer than necessary for the purposes set out in this policy. Different retention periods apply for different types of personal information.

When it is no longer necessary to retain your personal information, we will delete or shred it as necessary.

Record Retention: Records regarding this procedure must be maintained in accordance with InversePay's Data Retention Policy or as required by local or country regulations, whichever is longer.

Periodic Testing: Periodic testing on a risk-based frequency of the requirements of this procedure and testing criteria are determined under the AML Policy, in accordance with its requirements.

This section explains how InversePay ("we", "our", or "us") uses third-party software development kits (SDKs), device features, and system permissions on both iOS and Android platforms.

Identity Verification and Camera / Biometric Usage (iOS & Android): We use a third-party identity verification service, Smile ID, to perform KYC, authentication, and fraud-prevention checks.

On iOS devices, the Smile ID SDK uses Apple's TrueDepth camera and ARKit framework to capture face-related information, including 3D spatial orientation and facial expressions, during selfie capture. ARKit-based facial spatial orientation and expression data is processed locally on-device and is not transmitted to us or third parties.

On Android devices, Smile ID uses the device camera and platform-supported computer vision techniques for selfie capture and liveness detection. No Android biometric templates are accessed.

On both platforms, only required selfie images and document images needed for identity verification are securely transmitted to Smile ID in accordance with their privacy and security practices. We do not use this data for advertising, profiling, or unrelated purposes.

Camera Access: requested to enable QR code scanning, profile photo capture, and document capture for identity verification or transactions.

Biometric Authentication (Face ID / Touch ID / Android Biometrics): optional login security processed by operating-system frameworks; we do not access, store, or transmit biometric templates.

Location Services: with permission, we may collect approximate or precise location for country detection, address lookup, maps, or nearby agents.

Contacts Access: used only with explicit consent to find friends or invite contacts; not used for advertising.

Bluetooth Usage: may support nearby device interactions, such as proximity-based notifications or device discovery.

Photo Library / Media Access: used to select profile pictures or save transaction receipts based on your action.

Push Notifications: used for transaction alerts, confirmations, and security updates.

Analytics and Crash Reporting: may collect usage events, device type, OS version, app version, and crash diagnostics for reliability and improvements.

Device and App Information: we collect device model, OS version, app version, and user-agent data for compatibility, security, analytics, and diagnostics.

Secure Storage: sensitive information such as authentication tokens and credentials is stored using encrypted, system-provided secure storage mechanisms.

Data Sharing and Third Parties: data is shared with service providers only when necessary for app functionality, legal compliance, or service improvement. We do not sell personal data.

Your Choices and Controls: permissions can be managed or revoked at any time through device settings. Disabling permissions may limit some app features.

Our users' privacy is vital to us. We are committed to safeguarding the information entrusted to us and will continually update this policy to ensure that users' rights concerning personal information are respected.

If you have questions or comments about this Privacy Policy, please contact us at support@inversepay.app.