KongaPay Privacy Policy

1. Introduction

KongaPay and our affiliate companies (together "KongaPay" or "We" or "Our") are totally committed to protecting and respecting your privacy. We at KongaPay take the processing of your information very seriously and will use same strictly in the manner herein described. For the purposes of KongaPay's Privacy Policy, the term "information" refers to any confidential and/or personally identifiable or other information related to users of KongaPay Services (Customers and Merchants inclusive).

Our Privacy Policy, Terms and Conditions, and any other documents therein referred outline the basis through which any private data we collect from you, or provided to us by you, will be processed and utilized by us. Do read the information herein provided carefully to help you understand our procedures and practices in relation to your "personal data" and how these will be treated by us. Your information will not be sold or rented to third parties for purposes such as marketing without having first obtained your consent. Please note that in our pursuit to better serve you and enhance the quality of our services, we may under limited circumstances share some (only as necessary) of your information with third parties/partners under very strict stipulations. (Please read sections 3, 4, 5).

  • Updating our Privacy Policy and Notification of Changes:

    We reserve the right to revise our Privacy Policy over time to accommodate new/improved features which may be added to the KongaPay Services or as we incorporate suggestions from our customers. In light of this, we may choose to update, alter or amend this Privacy Policy at any time by posting a revised version on our website. We will provide you with at least 30 days' prior notice of the effective date of the revised privacy policy. In the event that we do not give you notice of an update to our privacy policy, we have a legal basis for such. The notice may be via email or "Policy Updates" page on our website. Your continued use of our services as of the effective date of the revised privacy policy, will be considered as you having consented to all changes. If you disagree with the terms, you may close your account at any time.

  • Third Party Websites:

    Any information you provide directly to a third party merchant, partner, website, or application is not covered by this privacy notice. We encourage you to review the privacy policies of any third party with whom you choose to share your personal information directly as we will not be responsible for their privacy or security practices. Please note that KongaPay will not collect information from children under the age of 18. All children must therefore be monitored by their parents and guardians.

2. Information We Collect From You

  • Information required from you: To use the KongaPay Services, you must provide certain information, which may be obtained when you fill forms our website and mobile applications during registration, participate in social media functions on our site, promotions, or surveys, or when you report a problem. This information includes, but is not limited to, your name, address, phone number, and email address. In order to make payments through the KongaPay Services, you must provide your photograph, financial, and debit card information. We may also request that you choose and answer different security questions.
  • Information collected while using your device to access KongaPay:The use of KongaPay Services on any device (e.g., laptops, phones, etc.) means we automatically collect technical information such as the Internet protocol (IP) address used to connect your computer to the Internet, your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform; the full Uniform Resource Locators (URL) clickstream to, through and from our site (including date and time); products you viewed or searched for; page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page and any phone number used to call our customer service number. Also, when you use KongaPay to send money/funds, we ask that you provide certain relevant information related to the transaction. We collect this information to cross-check the information provided to us to help detect possible instances of unauthorized transactions and to ensure that the cards and/or Financial information are not stolen.
  • Information relating to you collected from other sources: KongaPay verifies all the information you provide to protect all our customers from potential fraud. If you register a credit card, debit card, or bank account with KongaPay, we will verify your Bank Verification Number "BVN" from your bank, thereby confirming if your bank and card information match what is supplied by you to KongaPay and that the card has not been reported as lost or stolen. We may receive information about you if you use any of the other websites we operate or the other services we provide. We also work closely with third parties e.g., business partners, sub-contractors in technical, payment services, analytics providers, search information providers and may receive information about you from them.
  • Cookies, Web Beacons, Local Storage, and Similar Technologies: When you use KongaPay Services or access our website, we (including the partners we collaborate with) may place small data files on your computer or other devices (e.g., cookies, pixel tags, "Flash cookies," or other local storage provided by your browser). Cookies are used to recognize you as a Merchant, Buyer or User, customize KongaPay Services, content, measure promotional effectiveness, help ensure that your account security is not compromised, mitigate risk and prevent fraud, and to promote trust and safety across our website and the KongaPay Services offered to you. Please note that you are at liberty to decline cookies unless the cookies are specifically required to prevent fraud or ensure the security of the websites we control. However, declining our cookies may interfere with your use of KongaPay Services.
  • Account Information: For the purposes of this Privacy Policy, "Account Information" includes without limitation: name, address, email address, phone number, username, photograph, IP address, device ID, geolocation information, account numbers, account types, details of funding instruments associated with the account, details of payment transactions, details of commercial transactions, customer statements and reports, account preferences, details of identity collected as part of our "know your customer" verification on you, and customer correspondence.
  • Identity Verification Using TrueDepth API: Some of our identity verification Third-Party Providers collect personal data via our platform through Apple Inc.'s TrueDepth Application Programming Interface ("TrueDepth API") or other Identity Verification API's. This integration enables our platform utilize information automatically collected through the device camera on Apple's mobile devices.
    • The purpose of collecting this personal data is to track facial features and enhance the augmented reality (AR) experience during identity verification.
    • Specifically, we may use SmiledID to capture 3D spatial orientation and facial expressions to ensure that selfies submitted for authentication are from live users. This process is crucial for fraud prevention and secure user authentication. Importantly, all information processed via the TrueDepth API remains entirely local to your device. The spatial orientation and facial expression data are never transmitted to KongaPay, Third-Party Providers, or any external entity
    • Additionally, this data is not stored persistently on your device or elsewhere. We are committed to protecting your personal data and will take reasonable measures to ensure that all data provided by you and shared with Third-Party Providers comply with applicable data protection laws. We also ensure that any Third-Party Provider with whom we share your personal data upholds similar security standards as outlined in this Policy and under relevant data protection regulations.

3. Use Of Information We Collect From You

Internal Uses:

We collect, store, and process your information for various purposes, including:

  • Verification of your identity, including during account creation and password reset processes.
  • Processing transactions and provision of the KongaPay Services.
  • Managing, preventing, and detecting risk and/or remediating fraud or other potentially illegal or prohibited activities.
  • Resolution of disputes, collection of fees, and troubleshooting problems.
  • Detecting, preventing, or remediating violations of policies or applicable user agreements.
  • Providing quality customer support services.
  • Improving KongaPay's Services by customizing your user experience.
  • Measuring the performance of our Services and improving their content and layout.
  • Managing and protecting our information technology infrastructure.

The use of questionnaires, surveys, and your profile data is to improve KongaPay Services or as otherwise explained in detail in the survey itself. However, you may choose not to complete surveys or questionnaires.

Communication with KongaPay Customers:

We communicate with our users via email (sometimes SMS) to provide requested services.

  • Resolve all customer complaints or claims made by users of the KongaPay Services.
  • Send you notices of payments that you send or receive through KongaPay.
  • Respond to all requests for customer service.
  • Inform users if we believe their accounts have been compromised or any of their transactions have been used for an illegitimate purpose.
  • Confirm information concerning a user's identity, business, or account activity.
  • Conduct customer surveys.
  • Investigate any suspicious transactions.

We send emails to you to:

  • Confirm your subscription to our KongaPay services.
  • Send you notices of payments that you send or receive through KongaPay.
  • Send you information about important changes to our products and services.
  • Send notices and other communiques as required by law.

We also use your email address to send you other types of communications including "News from KongaPay", customer surveys, and notice of special third-party promotions.

In connection with independent audits of our financial statements and operations, the auditors may seek to contact a sample of our customers to confirm that our records are accurate. However, these auditors cannot use personally identifiable information for any secondary purposes.

4. Sharing your information with other KongaPay users

A duly registered KongaPay user's information is made available to other KongaPay customers whom you have paid or senders who are attempting to pay using KongaPay's services. This information includes name and contact details (if applicable). If you are a Business account holder, we will also display to other KongaPay customers the website address (URL) and customer service contact information that you provide us. In addition, this and other information may also be shared with third parties when you use these third parties to access KongaPay Services. However, your debit/credit card number, bank account, and other financial information will not be revealed to anyone whom you have paid or who has paid you through the KongaPay Services or third parties that use the KongaPay Services, except with your express permission or if we are required to do so pursuant to debit/credit card rules, a court order, or other legal process.

If you log into external websites or mobile apps via KongaPay, we may share your login status with any third party offering this Service as a login method, as well as the personal and other Account Information that you consent to being shared so that the third party can recognize you.

Please note that KongaPay will not give such third party access to your KongaPay Account and payments will only be made from your Account to that third party with your consent upon specific authorization given by you. Do note that you have total control over the settings for any such data sharing when logged into your KongaPay account.

We work with third parties including merchants to enable them to accept or facilitate payments from or to you using Our Services. In doing so, a third party may share information about you with us such as your email address or phone number, when a payment is sent to you or when you are attempting to pay that third party. We in turn use this information to confirm that you are a KongaPay customer and that KongaPay can be enabled to make a payment, or where a payment is sent to you to send you a notification that you have received a payment. Also, if you request that we validate your status as a KongaPay customer with a third party, we will do so. Please note that third parties you buy from and contract with may have their own privacy policies, and KongaPay is not responsible for their operations, including but not limited to their information practices.

Acceptance of this Privacy Policy, means you expressly agree and consent that each time you pay or attempt to pay another KongaPay customer (including a merchant) using your KongaPay account, KongaPay may transfer the aforementioned relevant data to such KongaPay customer.

In order to process, execute, or otherwise deal with and provide information about the payment, you also expressly agree and consent to KongaPay providing transactional information and other information necessary for the use of a KongaPay mobile application (including point of sale products) to a merchant or another KongaPay customer who you have explicitly selected or chosen using the KongaPay mobile application or point of sale product.

5. When And How We Share Information With Third Parties

KongaPay works with third-party service providers who provide important services that enable us to offer easier, faster, and safer ways to make payments. In light of this, we will only disclose user data as needed to enable them to perform the services required.

You specifically give your consent to KongaPay to do any and all the following with your information:

  • Disclosure of necessary information to: the police and other law enforcement agencies; security forces; competent governmental bodies (other than tax-related authorities), regulatory authorities, and other third parties, including KongaPay affiliates, where it is deemed appropriate for investigations of fraud, illegal activities, or violations of our Terms and Conditions.
  • We and other organizations, including parties that accept KongaPay, may also share, access, and use necessary information to help prevent fraud, money laundering, and terrorist financing. These agencies include but are not limited to the Special Frauds Unit (SFU) and the Economic and Financial Crime Commission (EFCC).
  • We will disclose necessary information in response to the requirements of a civil or criminal legal process.
  • If you, as a merchant, use a third party to access or integrate KongaPay, we may disclose to such a partner necessary information to facilitate and maintain such an arrangement (e.g., the status of your KongaPay integration or account activity).
  • Disclosure of necessary information to payment processors, auditors, customer service providers, fraud agencies, financial products providers, commercial partners, operational services providers, agencies, marketplaces, and other third parties. The purpose of this disclosure is to allow us to provide KongaPay Services to you.
  • Customer Service: For customer service purposes, including servicing your accounts or resolving disputes (e.g., billing or transactional issues).
  • Mergers or Acquisitions: If KongaPay merges with or is acquired by another company, you consent to the successor company accessing the information maintained by KongaPay, including customer Account Information. The successor company will continue to be bound by this Privacy Policy unless amended.
  • Third Party Sites: If you open a KongaPay account directly on a third-party website or via a third-party application, any information entered on that platform will be shared with its owner. These sites are governed by their own privacy policies, and KongaPay is not responsible for their content or information practices.

6. Protection Of Information

KongaPay is entirely committed to protecting the information we collect from you. We maintain appropriate administrative, technical, and physical safeguards (e.g., firewalls, data encryption, competent security guards etc.) All this is in place to prevent accidental, unlawful, or unauthorized destruction, loss, alteration, access, disclosure, or use.

Please note that you are vested with the responsibility of protecting your password in its entirety as communicated in our Terms and Conditions. You must not share your KongaPay Password with anyone. We will never request for your passwords via email or SMS. In the event you receive such communiques, please disregard and forward same communiques to [email protected]. In the event you share your password with a third party, you will be held responsible for the consequences. If you believe your password has been compromised please change it immediately and contact us.

7. Our Contact

KongaPay ensures that our day-to-day processes comply with this privacy policy and we are always available to address any questions or inquiries in relation to this 'Privacy Policy'. You can contact us to update information we have about you. Please Fsend an email to or call us on or .