Privacy Policy

Introduction

LitePay Ltd. ("LitePay," "we," "our," or "us") is committed to protecting your privacy and safeguarding your personal information. This Privacy Policy outlines how we collect, use, disclose, and protect your personal information when you access or use our website, mobile applications, and payment services (collectively, the "Services").

This Privacy Policy applies to all jurisdictions where we operate, and we comply with local data protection laws, including the UK GDPR, EU GDPR, CCPA/CPRA, Nigeria NDPR, and other applicable regulations.

By accessing or using the Services, you acknowledge that you have read and understood this Privacy Policy. Where required by law, we will seek your explicit consent for certain types of data processing (e.g., biometric data, marketing communications). If you do not agree with this Privacy Policy, please refrain from using our Services.

JURISDICTIONAL COVERAGE

This Privacy Policy is designed to comply with privacy laws in the jurisdictions where we operate, including: United Kingdom

(UK General Data Protection Regulation and Data Protection Act)
European Union (General Data Protection Regulation - GDPR)
United States (California CCPA/CPRA and other state laws)
Nigeria (Nigeria Data Protection Regulation - NDPR)
Ghana (Data Protection Act)
Kenya (Data Protection Act)
South Africa (Protection of Personal Information Act - POPIA)
Canada (Personal Information Protection and Electronic Documents Act - PIPEDA)

In each jurisdiction, the data controller responsible for your personal information is the relevant LitePay entity. For example:

LitePay UK Ltd - acts as the data controller for users in the United Kingdom.
LitePay Nigeria Ltd - acts as the data controller for users in Nigeria.

INFORMATION WE COLLECT

We collect the following categories of personal information:

1. Personal Information

Includes information that identifies or relates to you as an individual:

Full name
Date of birth
Address (home or business)
Email address
Phone number
Government-issued identification (passport, national ID, driver's license)
Biometric data (e.g., fingerprints, facial recognition - collected with explicit consent)
Photographs (for identity verification)
Nationality and country of residence
Tax identification information
Employment information

2. Financial Information

Includes financial and transactional data:

Bank account numbers
Credit/debit card information
Transaction history
Account balances
Source of funds information
Recipient details (name, account number, contact information)

3. Identity Verification Information

To comply with AML/KYC regulations:

Copies of identification documents
Proof of address documents
Politically exposed person (PEP) status
Sanctions screening data
Beneficial ownership information (for business accounts)

4. Device and Usage Information

We collect information about your devices and usage patterns:

IP address
Device identifiers
Location data (with your permission)
Browser type and version
App usage data
Access times and dates

5. Communications Data

Includes data related to interactions with our platform:

Customer support interactions
Email correspondence
In-app messages
Call recordings (with your knowledge and consent)

HOW WE COLLECT INFORMATION

We collect information through the following methods:

Directly from You: When you register, complete transactions, or upload verification documents.
Automatically: Through cookies, server logs, and analytics tools.
From Third Parties: Such as banks, identity verification services, and government agencies.

HOW WE USE YOUR INFORMATION

We process your personal data for the purposes and legal bases outlined below:

1. Provide Our Services

Purpose: To process transactions, verify your identity, and comply with AML/KYC obligations.
Legal Basis: Contractual necessity and compliance with legal obligations.

2. Improve Our Services

Purpose: To analyze usage patterns, develop new features, and optimize performance.
Legal Basis: Legitimate interests.

3. Marketing Communications

Purpose: To send promotional content and advertisements.
Legal Basis: Consent (explicitly obtained where required).

4. Fraud Prevention and Security

Purpose: To detect and prevent unauthorized transactions, fraud, and suspicious activities.
Legal Basis: Legitimate interests and compliance with legal obligations.

LEGAL BASES FOR PROCESSING (WHERE APPLICABLE)

Where required by law, we rely on the following legal bases to process your data:

Contractual Necessity: To provide our Services and fulfill contractual obligations.
Legitimate Interests: For purposes such as improving our Services and fraud prevention.
Compliance with Legal Obligations: To meet regulatory requirements (e.g., AML laws).
Consent: For activities requiring explicit consent, such as marketing or biometric data collection.

DATA SHARING AND DISCLOSURE

We share personal data with:

Service Providers: Such as payment processors, cloud hosting providers, and identity verification services.
Financial Partners: Including banks, mobile money providers, and card networks.
Regulators: As required by law for audits, investigations, or legal proceedings.
Business Transfers: In the event of mergers, acquisitions, or asset sales.

Third-Party Roles: Certain third parties (e.g., banks) may act as independent controllers for their processing activities.

INTERNATIONAL DATA TRANSFERS

LitePay operates globally, which means your data may be transferred to jurisdictions with different data protection laws. We use safeguards such as:

Standard Contractual Clauses (SCCs) for transfers outside the EEA.
Binding Corporate Rules (where applicable).
Obtaining explicit consent for certain transfers.

DATA SECURITY

We implement robust security measures, including:

Encryption (in transit and at rest).
Multi-factor authentication.
Regular security audits and penetration testing.

DATA RETENTION

We retain your data for as long as necessary to:

Provide our Services.
Comply with legal obligations (e.g., 5-10 years for AML records).

When no longer required, we securely delete or anonymize your data.

YOUR PRIVACY RIGHTS

Depending on your jurisdiction, you may have the following rights:

Access: Request a copy of your personal data.
Correction: Request correction of inaccurate data.
Erasure: Request deletion of your data in certain circumstances.
Objection: Object to processing for direct marketing.
Data Portability: Receive your data in a portable format.

To exercise your rights, contact us at privacy@mylitepay.net.

COOKIES AND SIMILAR TECHNOLOGIES

We use cookies to enhance your experience. You can manage cookie preferences through your browser settings or our website.

CHANGES TO THIS PRIVACY POLICY

We may update this policy periodically. Significant changes will be communicated via email or in-app notifications.

CONTACT INFORMATION

For privacy-related inquiries, contact us at:
Email: privacy@mylitepay.net
Data Protection Officer (DPO): dpo@mylitepay.net