Privacy Policy

1. Who is responsible for your data

ZYND SARL, which operates ZyndPay and is identified in section 1 of our Terms of Service, is the controller of the personal data described in this policy. We apply Mali’s personal data protection law (Law No. 2013-015 of 21 May 2013) and, where they apply to you, other data protection laws, such as the GDPR for people in the European Union.

When you pay a merchant through ZyndPay, we process your payment data on behalf of that merchant, which is responsible for informing you about its own use of your data. We remain responsible for the processing we carry out for our own purposes, such as fraud prevention, security and legal obligations.

For any question about this policy or your data, contact privacy@zyndpay.io.

2. Data we collect

Data you give us

• Account: name, phone number, email address, language and your sign-in credentials.
• Verification: identity documents and the information they contain, date of birth, nationality and address. For businesses: registration documents, and information about beneficial owners, directors and representatives. Where required, information about the source of funds.
• Payments and wallet: operations, amounts, currencies, recipients and senders, mobile money numbers, external wallet addresses, quotes and payment references.
• P2P marketplace: your offers and orders, the identity shown to your counterparty, order chat messages, proof of payment and dispute evidence.
• Vaults and tontines: your goals, the groups you join, contributions and payouts.
• Business accounts: team members and their roles, products and payment links, API and webhook settings, and, for Telegram subscriptions, your channel or group and subscriber information.
• Support and contact: your messages, complaints and the information you choose to share with us.

Data we collect when you pay a merchant

Depending on what the merchant asks for: name, email address, phone number, payment method and payment status. Card details are passed to our card payment partner to authorise the payment. We do not store full card numbers or security codes.

Data collected automatically

• Device and security: IP address, device information and sign-in activity, used to protect your account.
• Technical data: information about how our services respond and about errors, used to keep the Services working and secure, including in the business dashboard, where it never includes what you type.
• Cookies and similar technologies: see our Cookie Policy.

Data we receive from others

Payment partners (payment status and payer details), other users (for example when they send you money or open a P2P order with you), merchants, and sanctions and politically exposed persons lists.

Public contact form

If you send a question through our website, we collect your name, email address, subject, message and language to respond to you, and limited technical data to prevent abuse of the form.

3. Why we use your data

We do not sell your personal data and do not use it for third-party advertising.

4. Automated fraud checks

We use automated rules to detect fraud and financial-crime risk. They may delay or block an operation until it is reviewed. Identity documents are reviewed and decisions to refuse or close an account are made by our team. You may ask for a person to review a decision that affects you and give your point of view.

5. Who receives your data

• Other users and merchants, to the extent needed for an operation: for example, the name of the recipient of a transfer, or of the counterparty in a P2P order.
• Payment partners: mobile money operators, payment aggregators, card processors and blockchain networks that carry out your operations.
• Service providers acting on our instructions: technical infrastructure, communications, compliance checks and technical support tools. They may use your data only to provide their service to us.
• Authorities, where the law requires it, including financial intelligence units, judicial authorities and regulators.
• Professional advisers and auditors, under a duty of confidentiality.
• A successor, if all or part of our business is transferred, under the same protections.

Blockchain transactions are public by nature: addresses, amounts and transaction identifiers recorded on a blockchain can be seen by anyone. This is not a disclosure by ZyndPay.

6. International transfers

Your data may be processed outside your country, by us or by our service providers. We do so only where the law allows it, with appropriate safeguards, and with the authorisation of the competent data protection authority where it is required.

7. How long we keep your data

• Account data: for as long as your account is open, then as long as needed for the periods below.
• Identification, verification and transaction records, including P2P chats and dispute evidence: 10 years after the end of our relationship or after the operation, as required by anti-money laundering law.
• Technical data: for short periods, then deleted.
• Contact form requests: for as long as needed to handle your request, unless the law requires longer.

We may keep data longer where a law, a dispute or an investigation requires it. At the end of the retention period, we delete data or make it anonymous.

8. Security

We protect your data with measures suited to the risk, including encryption, restricted access and continuous monitoring. No system is perfectly secure. If a breach is likely to put you at risk, we inform you and the competent authorities as the law requires.

You can help protect your account: never share your password, PIN or verification codes, and tell us immediately if you think your account has been compromised.

9. Your rights

Subject to the conditions set by law, you can ask us to:

• access the personal data we hold about you and receive a copy;
• correct inaccurate or incomplete data;
• delete your data, unless we must keep it, for example under anti-money laundering law;
• stop processing your data for legitimate reasons, and stop any marketing at any time;
• receive the data you have given us in a usable format, where the law provides for this;
• have a person review a decision made by our automated fraud checks;
• withdraw your consent where we rely on it.

Write to privacy@zyndpay.io from the email address linked to your account, or through the app. We may ask you to confirm your identity. We respond within one month.

You may also lodge a complaint with the Autorité de Protection des Données à caractère Personnel (APDP) in Mali or with the data protection authority of your country.

Delete your ZyndPay account and data

You can request deletion of your ZyndPay account and associated personal data without reinstalling the app. Email privacy@zyndpay.io with the subject "Delete my ZyndPay account" and the phone number linked to your account. If you have a registered email address, write from that address. We will verify that you own the account before processing the request. Never send your PIN, password or verification codes.

In the app, open Profile, then Settings, then Delete my account. Read the consequences and confirm with your PIN. Account deletion is blocked while your wallet holds funds: withdraw your balance before proceeding. If you cannot sign in or withdraw, contact privacy@zyndpay.io for help.

Deletion closes your account and removes your access. Personal data that is no longer required is deleted or anonymised. Identity and verification records, transaction records, P2P chats and dispute evidence are retained for 10 years after the end of our relationship or the operation, as described in section 7. Data subject to a legal obligation, dispute or investigation may be retained longer.

You can also request deletion of particular personal data without closing your account by emailing privacy@zyndpay.io and identifying the data concerned. Legal retention requirements still apply. We respond within one month, as described in section 9.

10. Children

The Services are for people aged 18 and over. We do not knowingly collect data from children. If you believe a child has given us personal data, contact privacy@zyndpay.io and we will delete it.

11. Changes to this policy

We update this policy when our practices or the law change. We inform you of important changes by email or in the app or dashboard before they take effect. The date at the top of this page shows the latest version.

12. Contact

Personal data questions and requests: privacy@zyndpay.io.