1. Introduction

PayAngel is the trading name of PAYINC GROUP LIMITED and its affiliated entities (“we,” “our,” or “us”). We are committed to protecting your privacy and handling your personal data in a lawful, transparent, and fair manner. This Privacy Policy describes how we collect, use, disclose, and safeguard your personal data when you use our services and websites, and it reflects the data protection laws applicable in the jurisdictions we operate: the United Kingdom, European Union, United States, Canada, Australia, Ghana, Kenya and others.

2. Who We Are

PAYINC GROUP LIMITED is a global financial technology group providing cross-border payment and remittance services under the PayAngel brand. This Policy applies to PAYINC GROUP LIMITED and its affiliated companies operating under the PayAngel brand, including:

• PAYINC GROUP LIMITED (United Kingdom)
• PAYINC US CORP (United States)
• PAYANGEL FINANCIAL ?SOLUTIONS LIMITED (European Union)
• PAYINC (CA) LIMITED (Canada)
• PAYANGEL PTY LTD (Australia)
• PAYINC GHANA LIMITED (Ghana)
• PAYINC EAST AFRICA LIMITED? (Kenya)
• PAYANGEL KE MONEY TRANSFERS LIMITED (Kenya)

All references to “PayAngel” in this policy refer to PAYINC GROUP LIMITED and its group entities, affiliates and related companies, each of which may act as data controllers or processors depending on your location and services used.

3. Data We Collect

We may collect and process the following categories of personal data:

• Identity and Verification Data: Full name, date of birth, ID/passport, photos, nationality, national ID numbers and/or other KYC documents

• Contact Information: Email, address, phone numbers.
• Financial and Transaction Data: Bank account details, transaction history, payment instructions.
• Device and Technical Data: IP address, browser, device type, location data.
• Usage Data: Cookies and Information about how you use our platform or interact with our services.
• Sensitive Data: Where legally required or permitted, biometric or government-issued IDs.

• Location Data: Where permitted, geolocation from your device

4. How We Collect Your Data

We collect personal data:

• Directly from you when you register or use our services
• Automatically when you interact with our website or mobile apps
• From third parties including identity verification providers, financial institutions, and regulatory authorities

5. How We Use Your Data

Your data is used for the following lawful purposes:

• To provide our products and services
• To verify your identity and perform KYC/AML checks.
• To comply with legal and regulatory obligations
• To detect and prevent fraud and abuse
• To communicate with you about your account

• To Improve and personalize your experience.

6. Legal Basis for Processing

Depending on your jurisdiction, we process your data based on:

• Your consent
• Contractual necessity
• Legal obligations
• Legitimate interests (provided they don’t override your rights)

7. Data Sharing and Disclosure

We may share your data with:

• Payment processors, financial institutions, and identity verification services
• Our group entities and affiliates
• Government agencies or regulators where required
• Service providers assisting with operations (e.g., cloud services, analytics)

SMS Data Privacy

We will not share your opt-in to an SMS campaign with any third party for purposes unrelated to providing you with the services of that campaign. We may share your Personal Data, including your SMS opt-in or consent status, with third parties that help us provide our messaging services, including but not limited to platform providers, phone companies, and any other vendors who assist us in the delivery of text messages.

8. International Data Transfers

Because PayAngel operates globally, your personal data may be transferred and processed outside your country of residence. Where your data is transferred internationally, we ensure safeguards such as Standard Contractual Clauses, adequacy decisions, or other lawful mechanisms are in place.

9. Data Retention

We retain data only as long as necessary to fulfil the purposes for which it was collected, including for business, legal, and regulatory reasons (typically 6 years after your relationship with us ends). We then securely destroy or anonymize it.

10. Data Security

We apply technical and organizational safeguards such as:

• Encryption
• Access controls
• Secure hosting
• Continuous monitoring

11. Your Rights by Jurisdiction

A. UK & EU (UK GDPR / EU GDPR)

• Right to access, rectify, or erase your data
• Right to restrict or object to processing
• Right to data portability
• Right to lodge a complaint with the ICO or your local data protection authority

B. United States (e.g., CCPA)

• Right to know what information is collected and shared
• Right to delete your data
• Right to opt out of data selling (if applicable)
• Right to non-discrimination for exercising your rights
• We do not sell personal data

C. Canada (PIPEDA)

• Right to access and correct your data
• Right to withdraw consent
• Right to lodge complaints with the Office of the Privacy Commissioner of Canada

D. Australia (Privacy Act and APPs)

• Right to know how your data is used
• Right to access and correct your data
• Right to lodge complaints with the Office of the Australian Information Commissioner (OAIC)

E. Ghana (Data Protection Act, 2012 - Act 843)

• Right to be informed about data use
• Right to object or restrict processing
• Right to access and correct your data
• Right to complain to the Ghana Data Protection Commission

F. Kenya (Data Protection Act, 2019)

• Right to be informed of data collection and processing
• Right to access and correct your personal data
• Right to data portability
• Right to object to or restrict processing
• Right to lodge a complaint with the Office of the Data Protection Commissioner (ODPC)

12. Cookies and Tracking

We use cookies and similar technologies to enhance your user experience. You can manage your preferences through your browser or our [Cookie Settings Tool]. For full details, please refer to our Cookies Policy.

13. Children’s Privacy

Our services are not intended for individuals under 18. We do not knowingly collect data from children without parental consent.

13. Contact Information

To exercise your data rights or raise a privacy concern, contact the relevant team below:

14. Updates to This Policy

We may update this Privacy Policy from time to time. Updates will be published on our website with a revised effective date. Continued use of our services after changes constitutes acceptance of the revised terms.

Effective Date: 06 May 2025