1. Data we collect
- Account data: business details, beneficial owners, and the contact and login details of your team.
- KYB/verification data: identity documents, registration numbers (BVN/CAC and equivalents) and the results of verification checks.
- Transaction data: amounts, currencies, payment method, counterparties and settlement details needed to process and reconcile payments.
- Technical data: IP address, device and log data used to secure the service and prevent fraud.
2. How we use it
We process data to provide and secure the service, to run identity, sanctions and fraud checks, to settle funds, to meet legal and regulatory obligations, and to support and improve our products. For payment data, we act as a processor on your behalf and, where required by law, as a controller for compliance purposes.
3. Legal bases
Depending on the market, we rely on performance of a contract, our legitimate interest in operating a secure payments network, and compliance with legal obligations (such as anti-money-laundering law). We do not sell personal data.
4. Sharing
We share data with the licensed banks and payment partners that execute transactions, with identity- and fraud-verification providers, with regulators and law enforcement where legally required, and with infrastructure vendors that host the service under contract. We require appropriate safeguards for any cross-border transfers.
5. Retention
We keep personal and transaction data for as long as needed to provide the service and to meet record-keeping obligations under financial-services law — typically several years after an account closes — then delete or anonymise it.
6. Your rights
Subject to local law, you may request access to, correction of, or deletion of your personal data, and object to certain processing. Because payment records are subject to mandatory retention, some requests may be limited. To exercise a right, contact us at the address below.
7. Contact
For privacy questions or data-subject requests, email privacy@harepay.click. If your data is processed by HarePay on behalf of a merchant, please also contact that merchant directly.