Bongo Payments Inc. Privacy Policy

Overview

Bongo Payments Inc. ("Bongo Payments", "we", "our", or "us") respects your privacy and is committed to protecting your personal information. This Privacy Policy explains how we collect, use, disclose, store, and protect your personal information when you use our website, mobile app, and related services ("Services").

By accessing or using our Services, you agree to the collection, use, and disclosure of your information in accordance with this Privacy Policy. If you do not agree, please do not use our Services.

1. Information We Collect

Information You Provide Directly

• Personal details: name, date of birth, nationality, occupation
• Contact information: email address, phone number, residential address
• Identification and verification details: government-issued ID and address information. We may verify your address using utility bills, bank statements, or electronic address verification methods, depending on the verification process applicable to your account.
• Transaction details: amount, currency, recipient details, payment methods
• Communication records: emails, messages, support inquiries, survey responses

Information We Collect Automatically

• Device data: IP address, device type, operating system, browser type
• Usage data: time of access, pages visited, clicks, referring websites
• Location data: if enabled, GPS data or inferred location from IP address
• Security logs: login attempts, failed verifications, suspicious activity logs

Information from Third Parties

We may collect information from trusted third-party services, including:

• Identity verification vendors
• Financial institutions or payment providers
• Sanctions and watchlist screening providers
• Marketing or analytics providers, where legally permitted

2. How We Use Your Information

We use your personal information to:

• Provide and operate the Services
• Verify your identity and meet compliance obligations, including KYC/AML
• Process payments, currency exchanges, and money transfers
• Detect, prevent, and investigate fraud, abuse, and suspicious activity
• Comply with applicable laws, regulations, and reporting requirements
• Communicate with you about your account, transactions, or support requests
• Personalize your user experience and improve our platform
• Send marketing communications, where legally permitted, with an opt-out option

3. How We Share Your Information

Service Providers

• Identity verification providers
• Payment processors and financial institutions
• Cloud hosting and infrastructure providers
• Security and fraud prevention partners
• Customer support platforms and communication tools

Legal and Regulatory Authorities

We may disclose your personal information to law enforcement, regulators, or other government agencies if required by law, subpoena, or legal process, or if we believe such disclosure is necessary to protect our rights or comply with obligations.

Affiliates and Partners

Where applicable, we may share limited data with trusted affiliates or partners who help us deliver services via API or integration, subject to confidentiality agreements.

Business Transfers

If Bongo Payments is involved in a merger, acquisition, sale of assets, or insolvency event, your information may be transferred as part of that transaction.

4. International Transfers

We store and process your information in Canada and may transfer data to trusted service providers located in other jurisdictions. Where such transfers occur, we ensure appropriate safeguards are in place, such as contractual protections and secure data handling procedures.

5. Data Retention

We retain your personal information for as long as necessary to:

• Provide you with the Services
• Comply with legal, regulatory, and audit obligations, including 7 years for financial and identity records
• Resolve disputes and enforce our terms

When data is no longer required, it is securely deleted or anonymized.

6. Security of Your Information

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

• Encryption of data in transit and at rest
• Multi-factor authentication
• Access controls and audit logging
• Regular vulnerability assessments and penetration testing

Despite our efforts, no system is completely secure. You are responsible for keeping your account credentials safe and notifying us immediately if you suspect unauthorized use.

7. Your Privacy Rights

Under Canadian privacy laws, you have the right to:

• Access your personal information
• Correct inaccurate or incomplete information
• Withdraw consent, where processing is based on consent
• File a complaint with the Office of the Privacy Commissioner of Canada (OPC)

To exercise your rights, contact us at: privacy@bongopay.ca.

8. Cookies and Tracking Technologies

We may use cookies, pixels, and similar technologies to:

• Authenticate sessions
• Remember user preferences
• Measure platform usage and performance
• Support marketing and analytics

You can modify your cookie settings through your browser. Some cookies are essential and cannot be disabled without affecting functionality.

9. Marketing Preferences

We may send you updates, offers, or promotions if you have opted in. You can unsubscribe at any time by clicking the "unsubscribe" link in the email or by contacting us. Even if you opt out, we may still send service-related messages, such as transaction receipts.

10. Children's Privacy

Our Services are intended solely for individuals who are at least 18 years of age. Bongo Payments does not knowingly collect, solicit, or store personal information from anyone under the age of 18. If you are under 18, you are strictly prohibited from using our Services or providing us with any personal information.

This means you must not:

• Use or attempt to register for a Bongo Payments account.
• Submit any personal information to us, including your name, address, telephone number, or email address.
• Use any features of our platform, such as payment services, P2P transfers, or support channels.
• Interact with any content or tools made available on the Bongo Payments app or website.

If we become aware that personal data has been collected or received from an individual under the age of 18, we will take immediate steps to reject the registration, close the account if applicable, and permanently delete the data from our records.

If you believe that we may have inadvertently collected information from or about a minor under the age of 18, please contact our Data Protection Office immediately at privacy@bongopay.ca, and we will promptly investigate and take appropriate action.

11. Changes to this Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices or legal requirements. When we do, we will revise the "Last Updated" date above and notify you where required. Continued use of the Services after any updates constitutes your acceptance of the revised Privacy Policy.

12. Contact Us

If you have any questions or concerns about this Privacy Policy or our data practices, please contact:

Bongo Payments Inc.
Website: www.bongopay.ca
Email: privacy@bongopay.ca
Support: info@bongopay.ca