Privacy Policy for LocaPay Limited

Last Updated: June 17, 2025

LocaPay Limited (“LocaPay,” “we,” “us,” or “our”) is committed to protecting the privacy and security of your personal information. This Privacy Policy describes how we collect, use, disclose, and protect the information we obtain from users of our website, services, and applications (collectively, the “Services”).

By accessing or using our Services, you agree to the terms of this Privacy Policy. If you do not agree with the practices described in this Privacy Policy, please do not use our Services.

1. Information We Collect

We collect various types of information to provide and improve our Services, including:

a. Information You Provide Directly:

• Account Information: When you register for an account, we collect information such as your name, business name, email address, phone number, physical address, and other contact details.
• Financial Information: To process payments and provide our financial services, we may collect bank account details, credit/debit card information, payment transaction details, and other financial data.
• Identity Verification Information: For compliance with regulatory requirements (e.g., KYC – Know Your Customer), we may request identification documents such as national ID, passport, business registration documents, and tax identification numbers.
• Communications: When you communicate with us through email, phone, or our support channels, we collect the content of your communications and any information you provide.
• Marketing Preferences: Information about your preferences for receiving marketing communications from us.

b. Information We Collect Automatically:

• Usage Data: We collect information about how you interact with our Services, including the pages you visit, the features you use, the time and date of your visits, and the referring website addresses.
• Device Information: We may collect information about the device you use to access our Services, including the IP address, device type, operating system, browser type, unique device identifiers, and mobile network information.
• Location Information: We may derive your general location from your IP address. With your consent, we may also collect precise location information from your mobile device.
• Cookies and Tracking Technologies: We use cookies, web beacons, and similar technologies to collect information, personalize your experience, analyze usage patterns, and deliver targeted advertising. For more information, please see our Cookie Policy below.

c. Information from Third Parties:

• We may receive information about you from third-party service providers, business partners, and publicly available sources, such as credit bureaus, identity verification services, and financial institutions, to help us verify your identity, assess risk, and prevent fraud.

2. How We Use Your Information

We use the information we collect for various purposes, including:

• To Provide and Maintain Our Services: To operate, maintain, and improve our website, platform, and payment processing services.
• To Process Transactions: To facilitate B2B settlements, card payments, and other financial transactions you initiate.
• To Manage Your Account: To create and manage your user account, provide customer support, and send you service-related communications.
• For Security and Fraud Prevention: To detect, prevent, and investigate fraudulent or unauthorized activities, and to protect the security and integrity of our Services and your data.
• For Compliance and Legal Obligations: To comply with applicable laws, regulations, legal processes, and governmental requests, including anti-money laundering (AML) and know-your-customer (KYC) requirements.
• To Improve and Personalize Services: To understand how you use our Services, develop new features, and personalize your experience.
• For Marketing and Communications: To send you promotional materials, newsletters, updates, and other information about our products and services, where permitted by law and in accordance with your preferences. You can opt-out of marketing communications at any time.
• For Analytics and Research: To perform data analytics, research, and statistical analysis to improve our business operations and service offerings.

3. How We Share Your Information

We may share your information with third parties in the following circumstances:

• With Service Providers: We share information with trusted third-party service providers who perform services on our behalf, such as payment processors, identity verification services, cloud hosting providers, analytics providers, and customer support providers. These service providers are contractually obligated to protect your information and use it only for the purposes for which it was disclosed.
• With Business Partners: We may share information with business partners for joint marketing activities or to offer integrated services, where appropriate and with your consent if required.
• For Legal Reasons: We may disclose your information if required to do so by law or in response to valid requests by public authorities (e.g., a court order or government agency).
• In Case of Business Transfer: In connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business by another company, your information may be transferred.
• With Your Consent: We may share your information with third parties when we have your explicit consent to do so.
• For Fraud Prevention and Security: To prevent fraud, manage risk, and comply with legal requirements related to anti-money laundering and counter-terrorism financing.

We do not sell your personal information to third parties.

4. Data Security

We implement robust technical and organizational security measures to protect your personal information from unauthorized access, use, disclosure, alteration, or destruction. These measures include:

• Encryption: Using industry-standard encryption for data in transit and at rest.
• Access Controls: Implementing strict access controls to limit access to your data only to authorized personnel.
• Regular Audits: Conducting regular security audits and vulnerability assessments.
• Employee Training: Providing regular data protection and security training to our employees.
• Firewalls and Intrusion Detection: Utilizing firewalls and intrusion detection systems to protect our networks.

While we strive to protect your personal information, no method of transmission over the internet or method of electronic storage is 100% secure. Therefore, we cannot guarantee its absolute security.

5. Data Retention

We retain your personal information for as long as necessary to fulfill the purposes for which it was collected, including for the purposes of satisfying any legal, accounting, or reporting requirements. To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

6. Your Rights

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

• Right to Access: The right to request copies of your personal data held by us.
• Right to Rectification: The right to request that we correct any inaccurate or incomplete information.
• Right to Erasure (Right to be Forgotten): The right to request the deletion of your personal data under certain conditions.
• Right to Restrict Processing: The right to request that we restrict the processing of your personal data under certain conditions.
• Right to Object to Processing: The right to object to our processing of your personal data under certain conditions.
• Right to Data Portability: The right to request that we transfer the data that we have collected to another organization, or directly to you, under certain conditions.
• Right to Withdraw Consent: Where we rely on your consent to process your personal data, you have the right to withdraw that consent at any time.

To exercise any of these rights, please contact us using the contact details provided in Section 9. We may require you to verify your identity before responding to your request.

7. Third-Party Websites

Our Services may contain links to third-party websites or services that are not operated by us. We have no control over, and assume no responsibility for, the content, privacy policies, or practices of any third-party sites or services. We encourage you to review the privacy policies of any third-party websites you visit.

8. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices or legal requirements. We will notify you of any material changes by posting the new Privacy Policy on this page and updating the “Last Updated” date. We encourage you to review this Privacy Policy periodically for any changes. Your continued use of our Services after any modifications to this Privacy Policy will constitute your acknowledgment of the modifications and your consent to abide and be bound by the modified Privacy Policy.

9. Contact Us

If you have any questions or concerns about this Privacy Policy or our data practices, please contact us at:

LocaPay Limited Nairobi, Kenya Email: info@locapay.co.ke Support: Support@locapay.co.ke Phone: +254 727 420999

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Cookie Policy

LocaPay Limited (“LocaPay,” “we,” “us,” or “our”) uses cookies and similar tracking technologies on our website and services. This Cookie Policy explains what cookies are, how we use them, and your choices regarding their use.

What are Cookies? Cookies are small text files that are placed on your computer or mobile device when you visit a website. They are widely used to make websites work, or work more efficiently, as well as to provide reporting information.

How We Use Cookies We use cookies for various purposes, including:

• Essential Cookies: These cookies are strictly necessary for the operation of our website and services. They enable basic functions like page navigation, security, and access to secure areas of the website. Without these cookies, the website cannot function properly.
• Performance and Analytics Cookies: These cookies collect information about how visitors use our website, such as which pages are visited most often, how long users spend on the site, and if they encounter any error messages. This helps us understand and improve the performance of our website. We may use third-party analytics services (e.g., Google Analytics) for this purpose.
• Functionality Cookies: These cookies allow our website to remember choices you make (such as your username, language, or region) and provide enhanced, more personal features. They can also be used to remember changes you have made to text size, fonts, and other parts of web pages that you can customize.
• Advertising and Targeting Cookies: These cookies are used to deliver advertisements more relevant to you and your interests. They are also used to limit the number of times you see an advertisement and help measure the effectiveness of advertising campaigns. They are usually placed by advertising networks with the website operator’s permission.

Third-Party Cookies In addition to our own cookies, we may also use various third-parties cookies to report usage statistics of the Service, deliver advertisements on and through the Service, and so on.

Your Choices Regarding Cookies You have the ability to accept or decline cookies. Most web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer. Please note that disabling cookies may affect the functionality of our website and services.

• You can typically find information on how to manage cookie settings in your browser’s “Help” or “Settings” menu.
• For more information about cookies and how to control them, you can visit www.allaboutcookies.org.

Consent By continuing to use our website, you consent to the placement of cookies on your device as described in this Cookie Policy. When you first visit our website, you may see a cookie consent banner providing you with choices regarding cookie usage.

Changes to Our Cookie Policy We may update our Cookie Policy from time to time. Any changes will be posted on this page with an updated “Last Updated” date.