Privacy Policy

Last Updated: January 2026

1. Introduction

ElRoi Pay ("we," "our," or "us") is committed to protecting your privacy. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you use our multi-rail payment infrastructure platform. By using ElRoi Pay, you agree to the collection and use of information in accordance with this policy.

2. Information We Collect

2.1 Personal Information

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

  • Full name, date of birth, and government-issued ID numbers
  • Contact information (email address, phone number, physical address)
  • Financial information (bank account details, mobile money numbers)
  • Employment information (employer name, salary details)
  • Biometric data (facial recognition for KYC verification)

2.2 Transaction Information

We collect information about your transactions, including payment amounts, recipients, timestamps, merchant details, and transaction history across all connected payment rails (mobile money, bank accounts, wallet).

2.3 Device and Usage Information

We automatically collect device information (IP address, device type, operating system), usage data (pages visited, features used, time spent), and location data (GPS coordinates for fraud prevention and service delivery).

3. How We Use Your Information

We use your information to:

  • Process payments and financial transactions
  • Verify your identity and comply with KYC/AML regulations
  • Assess creditworthiness for BNPL and Pay Later services
  • Detect and prevent fraud, money laundering, and security threats
  • Provide customer support and respond to inquiries
  • Generate certified financial statements upon request
  • Improve our services and develop new features
  • Send transactional notifications and service updates
  • Comply with legal obligations and regulatory requirements

4. Information Sharing and Disclosure

4.1 Service Providers

We share information with third-party service providers who perform services on our behalf, including payment processors, banking partners, mobile money operators, KYC verification services, cloud hosting providers, and fraud detection systems.

4.2 Regulatory and Legal Requirements

We may disclose your information to comply with legal obligations, respond to government requests, enforce our terms of service, protect our rights and property, and prevent fraud or illegal activities.

4.3 Business Transfers

In the event of a merger, acquisition, or sale of assets, your information may be transferred to the acquiring entity.

4.4 With Your Consent

We may share your information with third parties when you explicitly consent, such as when sharing a certified financial statement with a bank or embassy.

5. Data Security

We implement industry-standard security measures to protect your information:

  • End-to-end encryption for all transactions
  • Secure data storage with encryption at rest
  • Multi-factor authentication for account access
  • Regular security audits and penetration testing
  • Employee training on data protection and privacy
  • Compliance with PCI-DSS standards for payment processing

6. Your Rights and Choices

You have the right to:

  • Access and review your personal information
  • Request correction of inaccurate data
  • Request deletion of your account and data (subject to legal retention requirements)
  • Object to processing of your information for certain purposes
  • Withdraw consent for optional data collection
  • Export your transaction history and financial data
  • Opt-out of marketing communications

To exercise these rights, contact us at privacy@elroipay.com

7. Data Retention

We retain your information for as long as necessary to provide our services and comply with legal obligations. Transaction records are retained for a minimum of 7 years as required by financial regulations. KYC documents are retained for 5 years after account closure. Marketing data is retained until you opt-out or request deletion.

8. International Data Transfers

ElRoi Pay operates across multiple African countries. Your information may be transferred to and processed in countries other than your country of residence. We ensure appropriate safeguards are in place for cross-border data transfers in compliance with applicable data protection laws.

9. Children's Privacy

ElRoi Pay is not intended for individuals under the age of 18. We do not knowingly collect personal information from children. If we become aware that we have collected information from a child, we will take steps to delete such information.

10. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. We will notify you of material changes by email or through a prominent notice in the app. Your continued use of ElRoi Pay after changes become effective constitutes acceptance of the updated policy.

11. Contact Us

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

ElRoi Pay Data Protection Officer

Email: privacy@elroipay.com

Phone: +233 (0) 30 123 4567

Address: One Health Global Technologies FZ-LLC, Dubai, UAE

This Privacy Policy is governed by the laws of the jurisdictions in which ElRoi Pay operates, including Ghana, Nigeria, Kenya, and other African countries where we provide services.