Privacy Policy

3.1 Information you provide directly

We may collect information that you provide directly to us, including:

• Full legal name.
• Preferred name.
• Email address.
• Phone number.
• Date of birth.
• Residential address.
• Mailing address.
• Country of residence.
• Nationality or citizenship, where required.
• Occupation, employer, source of funds, source of wealth, and financial profile information, where required.
• Government-issued identification information, including ID type, issuing country, ID number, expiry date, and ID images.
• Selfie, liveness check, biometric verification output, or similar identity verification information where required by our identity verification partners.
• Tax identification information, where required.
• Immigration, residency, or visa-related information where relevant to a product or regulatory requirement.
• Bank account details, card details, payment account details, wallet addresses, recipient details, and transaction instructions.
• Credit-building and rent-reporting information, including subscription details, payment history, landlord or property details, tenancy-related information, and information required to report to credit bureaus.
• Documents such as bank statements, utility bills, proof of address, business registration documents, ownership documents, invoices, contracts, proof of source of funds, or other verification documents.
• Communications with customer support.
• Survey responses, waitlist answers, referral information, and feedback.
• Marketing preferences and communication preferences.

3.2 Business account information

If you apply for or use a Kobopay business account, merchant account, API account, corporate card program, FX account, invoicing account, or related business service, we may collect information about the business and individuals associated with the business, including:

• Business legal name.
• Trade name or DBA.
• Business registration number.
• Business address.
• Country of registration.
• Country or countries of operation.
• Industry, business model, website, product or service description.
• Business size, transaction volume, revenue range, expected payment flows, source of funds, and intended use of the Services.
• Names, contact details, dates of birth, addresses, identification documents, ownership percentages, roles, and signatures of beneficial owners, directors, officers, authorized representatives, administrators, and signatories.
• Corporate documents, including articles of incorporation, certificates of formation, registers of directors, registers of shareholders, operating agreements, partnership agreements, board resolutions, ownership charts, licences, tax documents, bank statements, and invoices.
• Customer, vendor, recipient, payer, beneficiary, and counterparty information necessary to process transactions.
• API credentials, user permissions, authorized-user records, logs, technical integration data, and account administration activity.
• Business risk, compliance, sanctions, adverse media, fraud, chargeback, dispute, and transaction monitoring information.

If you provide personal information about another person, including a beneficial owner, director, officer, employee, contractor, customer, payer, recipient, landlord, tenant, or business contact, you represent that you have the authority or consent required to provide that information to Kobopay and that you have provided any required notice to that person.

3.3 Information collected automatically

When you visit our website, use our app, interact with our platform, or use our APIs, we may automatically collect information such as:

• IP address.
• Device identifiers.
• Browser type and version.
• Operating system.
• App version.
• Device model.
• Language settings.
• Time zone.
• Approximate location derived from IP address or device settings.
• Pages viewed, links clicked, buttons tapped, referral URLs, session duration, and interaction events.
• Login attempts, authentication activity, security events, error logs, crash reports, and performance data.
• Cookie identifiers, analytics identifiers, and similar tracking technologies.
• API usage logs, request metadata, endpoint activity, system events, webhook activity, and integration logs.

We use this information to operate, secure, improve, measure, and personalize the Services, detect fraud, prevent unauthorized access, troubleshoot problems, and comply with legal obligations.

3.4 Information from third parties

We may receive information about you from third parties, including:

• Identity verification providers.
• Fraud prevention providers.
• Sanctions, politically exposed person, watchlist, and adverse media screening providers.
• Credit bureaus and credit reporting agencies.
• Banking partners, payment processors, card issuers, acquiring banks, remittance partners, liquidity providers, and other financial service providers.
• Blockchain analytics and transaction monitoring providers.
• Government registries, company registries, court records, public databases, and regulatory databases.
• Employers, landlords, property managers, business representatives, counterparties, senders, recipients, merchants, vendors, customers, and other transaction parties.
• Marketing partners, referral partners, analytics providers, and advertising platforms.
• App stores, device platforms, and social media platforms, where you interact with us through those channels.

The information we receive from third parties may include identity verification results, fraud scores, sanctions screening results, credit reporting information, bank account verification information, payment status information, business ownership information, and transaction-related information.

4.1 To provide and administer the Services

We use personal information to:

• Create, verify, maintain, and administer personal and business accounts.
• Provide multi-currency wallet features, payments, remittance services, FX services, invoicing services, business payment tools, card-related services, API access, credit-building services, rent-reporting services, and other Services.
• Process deposits, withdrawals, transfers, conversions, payments, refunds, chargebacks, reversals, disputes, and account adjustments.
• Display balances, transaction history, statements, receipts, confirmations, and reports.
• Provide customer support and resolve issues.
• Manage subscriptions, billing, fees, and account notices.
• Authenticate users and manage account access.
• Enable business account administration, user roles, permissions, and API integrations.

4.2 To verify identity and assess eligibility

We use personal information to:

• Verify identity.
• Verify address.
• Verify business registration and ownership.
• Confirm authority to act on behalf of a business.
• Conduct know-your-customer, know-your-business, and beneficial ownership checks.
• Assess eligibility for products, account limits, card programs, credit-building services, rent-reporting services, business tools, and higher transaction limits.
• Request additional documentation where required.

4.3 To comply with legal, regulatory, and risk obligations

We use personal information to comply with laws, regulations, rules, regulatory guidance, court orders, law enforcement requests, and contractual obligations, including obligations related to:

• Anti-money laundering and anti-terrorist financing.
• Sanctions screening.
• Fraud prevention.
• Suspicious transaction detection and reporting.
• Large transaction reporting, where applicable.
• Virtual currency transaction monitoring and reporting, where applicable.
• Electronic funds transfer reporting, where applicable.
• Payment service provider obligations.
• Consumer protection obligations.
• Credit reporting obligations.
• Tax, accounting, audit, and recordkeeping obligations.
• Regulatory examinations, inquiries, and supervisory requests.
• Complaint handling and dispute resolution.

4.4 To protect Kobopay, users, partners, and the financial system

We use personal information to:

• Detect, investigate, prevent, and respond to fraud, scams, account takeover, unauthorized transactions, security incidents, money laundering, terrorist financing, sanctions evasion, market abuse, and other illegal or harmful activity.
• Monitor transactions and account activity.
• Enforce our Terms of Service, acceptable use rules, account limits, and compliance policies.
• Protect the rights, property, security, and safety of Kobopay, our users, our partners, and others.
• Maintain platform integrity and operational resilience.

4.5 To report to credit bureaus and support credit-building services

If you enroll in a credit-building, rent-reporting, or related credit service, we may use and disclose personal information to:

• Create, administer, and report eligible credit-building accounts.
• Report payment history, account status, subscription status, tradeline information, rent payment information, and other permitted information to credit bureaus or credit reporting agencies.
• Verify rent, tenancy, landlord, property, or payment information.
• Correct, update, investigate, or dispute credit reporting information.
• Comply with credit reporting laws and bureau requirements.

By enrolling in credit-building or rent-reporting services, you authorize Kobopay and its service providers to collect, use, verify, disclose, and report the information necessary to provide those services, subject to applicable law and the specific consent language presented at enrollment.

4.6 To communicate with you

We use personal information to:

• Send account notices, transaction alerts, receipts, confirmations, service messages, security alerts, and policy updates.
• Respond to inquiries, complaints, disputes, and support requests.
• Send marketing communications where permitted by law and subject to your communication preferences.
• Invite you to surveys, pilots, beta programs, referral programs, or product feedback sessions.

You may unsubscribe from marketing communications at any time. You may still receive transactional, legal, security, and service-related communications.

4.7 To improve, personalize, and develop Services

We use personal information to:

• Improve user experience.
• Analyze usage patterns.
• Test new features.
• Develop new products.
• Personalize content, account prompts, product recommendations, and onboarding experiences.
• Conduct research, analytics, forecasting, and business planning.
• Train staff and improve customer support quality.

Where appropriate, we use aggregated or anonymized information for analytics and product development.

6.1 Service providers and processors

We may disclose information to vendors and service providers that perform services for us, including cloud hosting, data storage, analytics, customer support, identity verification, KYC/KYB, fraud prevention, sanctions screening, transaction monitoring, email delivery, SMS delivery, app analytics, payment processing, card processing, compliance tooling, cybersecurity, legal, accounting, audit, and professional services.

6.2 Financial service partners

We may disclose information to regulated financial institutions, banking-as-a-service providers, payment processors, remittance partners, card issuers, acquiring banks, settlement banks, custodians, liquidity providers, virtual asset service providers, blockchain infrastructure providers, and other financial service partners as needed to provide, process, settle, safeguard, reconcile, or support the Services.

6.3 Credit bureaus and credit reporting agencies

If you use credit-building, rent-reporting, or related Services, we may disclose information to credit bureaus, credit reporting agencies, landlords, property managers, verification providers, and other parties necessary to verify and report eligible account or payment information.

6.4 Business account parties

For business accounts, we may disclose information to account administrators, authorized users, beneficial owners, directors, officers, signatories, employees, contractors, auditors, accountants, legal advisors, and other persons authorized by the business account holder.

6.5 Counterparties and transaction participants

We may disclose limited information to senders, recipients, merchants, vendors, customers, beneficiaries, banks, payment networks, card networks, and other transaction participants as needed to complete, identify, verify, process, reverse, refund, dispute, or reconcile transactions.

6.6 Regulators, law enforcement, and legal recipients

We may disclose information to regulators, financial intelligence units, law enforcement agencies, courts, government authorities, tax authorities, dispute resolution bodies, credit bureaus, and other authorized parties where required or permitted by law, regulation, legal process, regulatory request, audit, examination, investigation, or enforcement action.

6.7 Corporate transactions

We may disclose personal information in connection with a merger, acquisition, financing, investment, reorganization, sale of assets, bankruptcy, due diligence process, or other corporate transaction involving Kobopay, subject to appropriate confidentiality and legal safeguards.

6.8 With your consent or direction

We may disclose information where you consent, direct us to do so, connect a third-party service, authorize data sharing, or otherwise instruct us to share information.