Privacy Policy
Last updated: August 11, 2025
SusuPay: Privacy Policy
Effective Date: August 11, 2025
Your privacy is important to us. This Privacy Policy explains how SusuPay ("we," "us," or "our") collects, uses, shares, and protects your personal information when you use our mobile application and services (the "Service").
1. Information We Collect
1.1. Information You Provide to Us:
Account Information: When you register, we collect your name, phone number, and email address.
Know Your Customer (KYC) Information: To use financial features, we collect your government ID (Ghana Card, Voter ID, or Passport) details, a recent utility bill, and contact information for two beneficiaries (name, phone number, relationship).
Financial Information: Details of your susu contributions, loan requests (amount, interest, purpose), and transaction history.
Collateral Information: For collateral loans, we collect descriptions, details, and photos of the items you list.
Communications: Any information you send to us, such as feedback or support requests.
1.2. Information We Collect Automatically:
Usage Data: Information about how you interact with our Service, such as features used, pages viewed, and the dates and times of your visits.
Device Information: We may collect information about your mobile device, including the hardware model, operating system, and unique device identifiers.
Transaction Logs: We maintain secure logs of all financial actions for audit and security purposes.
2. How We Use Your Information
We use your information for the following purposes:
To Provide and Manage the Service: To set up your account, verify your identity (KYC), process payments, manage escrow funds, and facilitate susu and loan agreements.
To Ensure Security and Prevent Fraud: To protect you and the platform from fraudulent activity, verify transactions, and enforce our Terms.
To Communicate With You: To send you transaction confirmations, service announcements, security alerts, and provide customer support.
To Improve Our Service: To analyze usage trends and feedback to improve the user experience and develop new features.
To Manage Our Referral Program: To track referrals, verify eligibility, and issue rewards.
3. How We Share Your Information
We do not sell your personal data. We may share your information in the following limited circumstances:
With Other Users: We share necessary information between users to facilitate a transaction. For example, a Lender will see a Borrower's loan request details and verified status. Your full KYC documents are not shared with other users.
With Third-Party Service Providers: We share information with trusted partners who perform services on our behalf, such as payment processing (Paystack), data hosting, and security analytics. These providers are only given access to the information necessary to perform their functions and are contractually obligated to protect your data.
For Legal Compliance and Safety: We may disclose your information if required by law, subpoena, or other legal process, or if we believe in good faith that disclosure is necessary to protect our rights, your safety, or the safety of others.
Business Transfers: In the event of a merger, acquisition, or sale of assets, your information may be transferred as part of that transaction.
4. Data Security
We are committed to protecting your information. We implement robust technical and administrative security measures, including:
Encryption: Your sensitive data, including KYC documents and passwords, is stored in an encrypted format. All data is encrypted in transit between your device and our servers.
Access Controls: Access to personal user data is strictly limited to authorized SusuPay personnel who require it to perform their job functions (e.g., KYC verification, dispute resolution).
While we take significant steps to secure your data, no electronic system is 100% secure.
5. Data Retention
We retain your personal information for as long as your account is active. After your account is closed, we will retain certain information (such as KYC and transaction history) for a period required to comply with our legal obligations, prevent fraud, and resolve disputes.
6. Your Rights and Choices
You have the right to:
Accessing and Updating Your Information: You have the right to access your personal information within the SusuPay app. For enhanced security, once your account is successfully verified through our KYC process, key personal details are locked to protect your account from fraud and unauthorized changes.
If you need to update this information (for example, due to a legal name change, new address, or new phone number), please contact our dedicated support team. We will assist you in securely verifying and making the necessary changes to your profile.
Account Deletion: You can request to delete your account by contacting our support team. Please note that we may be required to retain certain information for legal or security reasons as described in the Data Retention section.
7. Children's Privacy
Our Service is not intended for individuals under the age of 18. We do not knowingly collect personal information from children under 18.
8. Changes to This Privacy Policy
We may update this Privacy Policy from time to time. We will notify you of any changes by posting the new policy within the app and updating the "Effective Date."
9. Contact Us
If you have any questions or concerns about this Privacy Policy or our data practices, please contact us at: Privacy@earnsusupay.com
Effective Date: August 11, 2025
Your privacy is important to us. This Privacy Policy explains how SusuPay ("we," "us," or "our") collects, uses, shares, and protects your personal information when you use our mobile application and services (the "Service").
1. Information We Collect
1.1. Information You Provide to Us:
Account Information: When you register, we collect your name, phone number, and email address.
Know Your Customer (KYC) Information: To use financial features, we collect your government ID (Ghana Card, Voter ID, or Passport) details, a recent utility bill, and contact information for two beneficiaries (name, phone number, relationship).
Financial Information: Details of your susu contributions, loan requests (amount, interest, purpose), and transaction history.
Collateral Information: For collateral loans, we collect descriptions, details, and photos of the items you list.
Communications: Any information you send to us, such as feedback or support requests.
1.2. Information We Collect Automatically:
Usage Data: Information about how you interact with our Service, such as features used, pages viewed, and the dates and times of your visits.
Device Information: We may collect information about your mobile device, including the hardware model, operating system, and unique device identifiers.
Transaction Logs: We maintain secure logs of all financial actions for audit and security purposes.
2. How We Use Your Information
We use your information for the following purposes:
To Provide and Manage the Service: To set up your account, verify your identity (KYC), process payments, manage escrow funds, and facilitate susu and loan agreements.
To Ensure Security and Prevent Fraud: To protect you and the platform from fraudulent activity, verify transactions, and enforce our Terms.
To Communicate With You: To send you transaction confirmations, service announcements, security alerts, and provide customer support.
To Improve Our Service: To analyze usage trends and feedback to improve the user experience and develop new features.
To Manage Our Referral Program: To track referrals, verify eligibility, and issue rewards.
3. How We Share Your Information
We do not sell your personal data. We may share your information in the following limited circumstances:
With Other Users: We share necessary information between users to facilitate a transaction. For example, a Lender will see a Borrower's loan request details and verified status. Your full KYC documents are not shared with other users.
With Third-Party Service Providers: We share information with trusted partners who perform services on our behalf, such as payment processing (Paystack), data hosting, and security analytics. These providers are only given access to the information necessary to perform their functions and are contractually obligated to protect your data.
For Legal Compliance and Safety: We may disclose your information if required by law, subpoena, or other legal process, or if we believe in good faith that disclosure is necessary to protect our rights, your safety, or the safety of others.
Business Transfers: In the event of a merger, acquisition, or sale of assets, your information may be transferred as part of that transaction.
4. Data Security
We are committed to protecting your information. We implement robust technical and administrative security measures, including:
Encryption: Your sensitive data, including KYC documents and passwords, is stored in an encrypted format. All data is encrypted in transit between your device and our servers.
Access Controls: Access to personal user data is strictly limited to authorized SusuPay personnel who require it to perform their job functions (e.g., KYC verification, dispute resolution).
While we take significant steps to secure your data, no electronic system is 100% secure.
5. Data Retention
We retain your personal information for as long as your account is active. After your account is closed, we will retain certain information (such as KYC and transaction history) for a period required to comply with our legal obligations, prevent fraud, and resolve disputes.
6. Your Rights and Choices
You have the right to:
Accessing and Updating Your Information: You have the right to access your personal information within the SusuPay app. For enhanced security, once your account is successfully verified through our KYC process, key personal details are locked to protect your account from fraud and unauthorized changes.
If you need to update this information (for example, due to a legal name change, new address, or new phone number), please contact our dedicated support team. We will assist you in securely verifying and making the necessary changes to your profile.
Account Deletion: You can request to delete your account by contacting our support team. Please note that we may be required to retain certain information for legal or security reasons as described in the Data Retention section.
7. Children's Privacy
Our Service is not intended for individuals under the age of 18. We do not knowingly collect personal information from children under 18.
8. Changes to This Privacy Policy
We may update this Privacy Policy from time to time. We will notify you of any changes by posting the new policy within the app and updating the "Effective Date."
9. Contact Us
If you have any questions or concerns about this Privacy Policy or our data practices, please contact us at: Privacy@earnsusupay.com