Privacy Policy
Effective Date: March 1, 2026
1. Introduction
CA PAY Global (“App”, “Service”) is an Africa-first fintech super application operated by CA PAY Network (“Company”, “we”, “us”, or “our”). We are committed to protecting your privacy and safeguarding the personal data you entrust to us.
This Privacy Policy explains what information we collect, how we use it, who we share it with, how we protect it, and what rights you have regarding your data. By creating an account or using CA PAY Global, you consent to the practices described in this policy.
This policy applies to all users of the CA PAY Global mobile application, web application, and related services across all jurisdictions in which we operate.
2. Information We Collect
2.1 Account Information
Full name, email address, phone number, date of birth, country of residence, preferred language.
2.2 Identity Verification (KYC)
- Government-issued ID (passport, national ID, driver’s license)
- Proof of address
- Selfie for biometric verification
- Source of funds documentation (for enhanced due diligence)
2.3 Financial Data
- Transaction history
- Wallet balances
- Payment method details
- Exchange and trading activity
- Virtual card usage data
2.4 Device & Technical Data
- Device type and model
- Operating system and version
- IP address
- App version
- Browser type (for web access)
- Push notification tokens
2.5 Usage Data
- Features accessed and frequency of use
- Session duration and navigation patterns
- Search queries within the app
- Customer support interactions
- Language and localization preferences
3. How We Use Your Information
We use the information we collect for the following purposes:
- Process payments, deposits, withdrawals, and cross-border transfers
- Verify your identity through KYC procedures
- Facilitate peer-to-peer (P2P) cryptocurrency trading via escrow
- Issue and manage virtual debit cards
- Detect and prevent fraud, unauthorized access, and financial crimes
- Comply with Anti-Money Laundering (AML) and Counter-Terrorism Financing (CFT) regulations
- Provide customer support and resolve disputes
- Send transaction confirmations, security alerts, and service notifications
- Improve our services, fix bugs, and develop new features
4. How We Share Your Information
4.1 Regulatory & Legal
- Financial regulatory authorities (as required by law)
- Law enforcement agencies (pursuant to valid legal process)
- Tax authorities (where required by jurisdiction)
4.2 Service Providers
- Identity verification providers (for KYC processing)
- Payment processors and mobile money providers (MTN, Orange, M-Pesa, etc.)
- Card-issuing partners (for virtual card services)
- Cloud infrastructure providers (with data processing agreements)
- Analytics providers (aggregated, non-personal data only)
4.3 Business Transfers
In the event of a merger, acquisition, or sale of assets, your data may be transferred as part of the transaction. You will be notified of any such change.
4.4 With Your Consent
We may share information with third parties when you have given explicit consent, such as when connecting to partner services.
5. Data Security
Security Measures
- TLS/SSL encryption for all data in transit
- AES-256 encryption for all data at rest
- AES-256-GCM encryption for API keys and secrets
- Row-Level Security (RLS) policies on all database tables
- Comprehensive audit trail on all sensitive operations
- Multi-factor authentication for administrative access
- Regular security assessments and penetration testing
Data Residency
- Primary database: Supabase EU (aws-eu-west-1, Ireland)
- KYC documents: Encrypted storage with region-specific access controls
- Backups: Encrypted and stored in geographically separated locations
- Analytics: Firebase (Google Cloud, EU processing where available)
6. Your Rights
You have the following rights regarding your personal data:
- Right to Access: Request a copy of all personal data we hold about you
- Right to Rectification: Request correction of inaccurate or incomplete data
- Right to Erasure: Request deletion of your data (subject to legal retention requirements)
- Right to Restrict Processing: Request that we limit how we use your data
- Right to Data Portability: Receive your data in a structured, machine-readable format
- Right to Object: Object to processing of your data for certain purposes
- Right to Withdraw Consent: Withdraw previously given consent at any time
To exercise any of these rights, contact us at support@capayglobal.com. We will respond within 30 calendar days.
7. Data Retention
We retain your personal data only for as long as necessary to fulfill the purposes for which it was collected, comply with legal obligations, and resolve disputes:
| Data Type | Retention Period |
|---|---|
| Account data | Duration of account plus 5 years (regulatory requirement) |
| Transaction records | 7 years (financial regulations) |
| KYC documents | 5 years after account closure |
| Usage and analytics data | 2 years (aggregated thereafter) |
| Customer support records | 3 years |
8. Children's Privacy
CA PAY Global is not intended for use by individuals under the age of 18. We do not knowingly collect personal data from children. If we discover that a child’s data has been collected, we will take immediate steps to delete it.
9. International Data Transfers
As we operate across multiple countries, your data may be transferred to and processed in countries other than your country of residence. We ensure appropriate safeguards are in place, including standard contractual clauses and data processing agreements, to protect your data during international transfers.
10. Changes to This Policy
We may update this Privacy Policy from time to time. Material changes will be communicated through the application, via email, or through a prominent notice on our website. Your continued use of the Service after changes take effect constitutes acceptance of the updated policy.
11. Contact Us
If you have any questions, concerns, or requests regarding this Privacy Policy or how we handle your personal data, please contact us:
- Privacy Inquiries: support@capayglobal.com
- General Support: support@capayglobal.com
- In-App: Settings > Support > Contact Us
- Response Time: Within 30 calendar days
By using CA PAY Global, you acknowledge that you have read and understood this Privacy Policy and consent to the collection, use, and sharing of your information as described herein.
By using CA PAY Global, you acknowledge that you have read and understood this Privacy Policy and consent to the collection, use, and sharing of your information as described herein.