This Privacy Policy describes KIRAPAY's ("we", "our" or "us") policies and procedures regarding how your personal information is collected, used, and disclosed in connection with your use of the KIRAPAY payment services (the "App") and any associated services, features, content, or applications we offer through the App (collectively, the "Services"). We receive information about you from various sources, including: (i) when you register for the App or the Services through your user Account (your "Account"); (ii) your use of the Services; and (iii) from third-party websites and services. When you use the Services, you agree to the collection, use, and disclosure of your information as described in this Privacy Policy.

What Does This Privacy Policy Cover?

This Privacy Policy explains how we handle personally identifiable information ("Personal Information") when you use or access the Services. It also covers how we treat Personal Information shared with or by our Business Partners.

Information We Collect

We collect information to personalise, improve, protect, and operate the Services. This may include Personal Information. We collect the following types of information:

Account Information

When you create an Account, you may need to provide Personal Information such as your name and email address. By creating an Account, you allow us and others to identify you. We may use your contact information to send you information about our Services and may request additional identification information to comply with anti-money laundering obligations. You may unsubscribe from some communications by emailing us at support@kira-pay.com, though we reserve the right to contact you when necessary.

Google Authentication

If you link your Google account to our Services using Google Authentication, you will provide personal information to both our application and Google. This may include your name, email address, and other information available to Google. We use this information to provide and personalise our Services. Google will collect, use, and disclose your information according to its own privacy policy. By using Google Authentication, you agree to the collection, use, and disclosure of your information by both us and Google.

KYC (Know Your Customer)

To provide KYC functionality, we use Sumsub, a third-party service provider that collects and processes personal information including your full name and identification documents. This information is used solely for KYC verification and compliance with legal and regulatory requirements. Information is processed securely in accordance with Sumsub's privacy policy and applicable laws. We use this information to verify user identity and ensure service security. You have the right to access, modify, and delete your personal information collected through Sumsub, or request restricted processing. To exercise these rights, contact us using the information at the end of this policy.

Third-Party Services

You may interact with third-party applications while using the Services ("Third Party Service"). Your interactions with Third-Party Services are subject to their privacy policies. We encourage you to read the privacy policies of any Third-Party Services.

Cookies and Tracking Technologies

We may use third-party cookies, such as Google Analytics, for website traffic tracking and user targeting. You can opt-out by setting your browser to refuse cookies or notify you when a website tries to set a cookie. Disabling cookies may affect some features. Click here for more information on opting out of Google Analytics tracking.

Information Retention

We retain your information only as long as necessary for processing purposes or as required to comply with applicable laws.

Technical and Usage Information

We may collect technical and usage information such as IP addresses, visitor frequency, and Service usage patterns. We use this data in aggregate or anonymous forms that do not personally identify you. This helps us and authorized third parties understand how individuals use the Services.

Email Communications

We may send you communications via email (providing your email address is optional). We may gather information about these communications, such as open and click rates. When you provide your email address, you consent to receive communications including customer service notifications and newsletters.

Aggregate Information

We collect statistical information about how users interact with the Services ("Aggregate Information"). Some of this is derived from Personal Information, but the statistical information itself is not Personal Information and cannot be tied back to you, your Account, or your browser.

How We Use Your Personal Information

We use your personal information to:

• fulfil our contractual obligations and provide you with requested information and services

• comply with legal and regulatory obligations

• keep you informed about changes to our Services

• ensure the safety and security of our Services

• administer our Services and conduct internal operations such as troubleshooting, data analysis, testing, research, and surveys

• improve our Services and ensure effective presentation

• measure ad effectiveness and provide relevant advertising

• enable you to participate in interactive features of our Services

• notify you about similar items and services we provide

• provide you with information about goods or services you might be interested in, allow selected third parties to do the same, or combine information from various sources

Information Sharing

We may share personal information in the following circumstances:

• With vendors, service providers, and consultants who need access to provide services such as website hosting, systems monitoring, fraud prevention, identity verification, customer service, and marketing

• When required to comply with applicable laws, legal processes, or requests from public authorities, including law enforcement

• When we believe your actions do not align with our user agreements or policies, when we suspect you have broken the law, or to protect the rights, property, and safety of KIRAPAY, our users, and the public

• With our legal and professional advisors as necessary to secure legal advice or protect business interests

We may also share aggregated or de-identified information that cannot be used to identify you personally.

International Data Transfer

Our Services are operated primarily in the United Kingdom, and data may be transferred to recipients in the UK and elsewhere in the world. We comply with legal requirements and take all reasonably necessary steps to ensure your data is treated securely in cross-border transfers.

Your Data Protection Rights

You may decline to submit information through the Services, though this may prevent us from providing certain services. You have the right to access the information we hold about you, subject to relevant laws. You can exercise your right of access in line with applicable data protection legislation. You can request deletion of your data when it's no longer necessary or when subject to a legal obligation. You may email us at support@kira-pay.com to opt out of marketing communications.

EEA and UK

Residents of the European Economic Area ("EEA") and the United Kingdom can contact us as described below to exercise their rights within the scope of the General Data Protection Regulation (GDPR).

California Privacy Rights

California law permits California residents to request, once a year and free of charge, a list of third parties to whom we have disclosed their personal information for direct marketing purposes in the prior calendar year, as well as the types of personal information disclosed. If you are a California resident and would like to request this information, please send your request to support@kira-pay.com

Changes to This Privacy Policy

We may update this privacy policy from time to time to reflect changes to our practices or for other operational, legal, or regulatory reasons. We will provide you with reasonable notice of such changes via prominent notice in the Service or to your email address of record. Where required by law, we will obtain your consent or allow you to opt out of such changes.

Contact Us

For more information about our privacy practices, questions, or to make a complaint, please contact us by email at support@kira-pay.com.