SmartPayGo Ltd ("SmartPayGo," "we," "us," or "our") respects your privacy and is committed to protecting it through our compliance with this policy. This Privacy Policy describes the types of information we may collect from you or that you may provide when you use the SmartPayGo mobile application and related services (the "App"), and our practices for collecting, using, maintaining, protecting, and disclosing that information.
This policy is written to reflect how SmartPayGo actually works, including the fact that SmartPayGo does not hold, process, or have custody of your money at any point. Payments made through the App are carried out directly between you and the recipient through your mobile network operator's own USSD mobile money service (such as MTN MoMo and eKash). SmartPayGo only helps you initiate that transfer more conveniently and keeps a personal record of it for your own reference.
1. Information We Collect
We collect information in three ways: information you give us directly, information we collect automatically, and information generated by your own use of the App's features.
1.1 Information You Provide Directly
- Name provided when you create an account.
- Phone number used to create and verify your account via a one-time SMS code (OTP). Your phone number is also used as your identifier for peer-to-peer USSD payments you choose to make.
- Business information (if you register a business account) such as business name, business type, business phone number or MoMo/merchant identifier, and any supporting documents submitted during our business application review process.
- Payment context you enter such as the amount you intend to send, the category or purpose of a payment (e.g., "Groceries," "School Fees"), and the recipient you select or type in.
- Self-reported payment outcomes after you send money via USSD, we ask you to confirm whether the payment was successful. This confirmation, provided by you, is what determines whether a transaction is saved to your history.
- Communications information you provide when you contact our support team.
1.2 Information Collected Automatically
- Device and log data device model, operating system version, app version, IP address, and general diagnostic/crash information, used to keep the App working correctly and to fix problems.
- Usage data how you interact with the App's features, such as which screens you visit and how often you use the payment or reporting tools.
1.3 Information Collected Through Device Permissions
The App may request the following permissions, which you can grant or decline through your device settings:
- Camera used only to scan QR codes for payments (business QR codes, or your own QR code for receiving payments). We do not store camera images; we only read the QR code content at the moment of scanning.
- Phone/Dialer access used to open your device's own USSD dialer with the payment code pre-filled, so you can complete a transfer through your mobile network operator. SmartPayGo does not see or record your USSD PIN or any information exchanged between you and your mobile network operator during that dial session.
- Notifications used to alert you to payment confirmation reminders, category-selection reminders, and business account notifications.
1.4 What We Do NOT Collect
To be clear about the boundaries of our service:
- We do not collect or have access to your mobile money PIN.
- We do not process, hold, or have custody of funds transferred through the App at any point transfers occur directly between mobile money accounts via your network operator's own USSD system.
- We do not have visibility into whether a USSD transaction actually succeeded on your mobile network operator's side the transaction record in the App reflects what you or the receiving business confirm, not a verified bank-level record.
2. How We Use Your Information
We use the information described above to:
- Create and maintain your SmartPayGo account.
- Verify your identity your contact email when you sign up or log in.
- Let you initiate USSD payments and generate or scan QR codes for peer-to-peer or business payments.
- Maintain your personal transaction history, spending categories, and monthly budget tracking, based on the payment confirmations you provide.
- Review and approve business account applications, and provide business owners with dashboards showing their sales, customer counts, and bookkeeping summaries based on confirmed transactions.
- Generate electronic receipts for confirmed transactions between customers and participating businesses.
- Communicate with you about your account, respond to support requests, and send service-related notifications.
- Detect, investigate, and prevent fraudulent activity, misuse, or violations of our Terms of Service for example, verifying that a scanned QR code corresponds to a real, registered business before allowing a payment to proceed.
- Maintain, secure, and improve the App, including diagnosing technical issues.
- Comply with applicable law, including Rwandan financial and data protection regulations.
We do not sell your personal information.
3. How We Share Your Information
We may share your information in the following limited circumstances:
- With businesses you pay if you pay a registered business through the App, that business will see the payment details you provided (amount, your name/number if applicable) so they can confirm receipt of payment and issue you a receipt.
- Service providers we work with third-party providers for hosting, database services, and infrastructure (such as our backend and database provider) who process data on our behalf, under confidentiality obligations, solely to help us operate the App.
- Legal and regulatory reasons we may disclose information if required to do so by Rwandan law, regulation, legal process, or governmental request, including tax authorities (such as the Rwanda Revenue Authority, where applicable to registered businesses) or financial regulators.
- Business transfers if SmartPayGo is involved in a merger, acquisition, or sale of assets, your information may be transferred as part of that transaction, subject to this policy or a comparable one.
We do not share your personal information with third parties for their own independent marketing purposes.
4. Data Retention
We retain your personal information for as long as your account remains active, or as needed to provide you with the App's services. If you delete your account, we will delete or anonymize your personal information within a reasonable period, except where we are required to retain certain records for legal, tax, or regulatory compliance purposes (for example, transaction records that participating businesses may need to retain for tax reporting).
5. Data Security
We take reasonable technical and organizational measures to protect your information from loss, misuse, unauthorized access, disclosure, or alteration, including access controls on our database and encryption of data in transit. However, no method of electronic transmission or storage is completely secure, and we cannot guarantee absolute security.
You are responsible for keeping your device secure and for the confidentiality of any authentication codes (such as OTP codes) sent to your phone.
6. Your Rights
Under Rwanda's Law N° 058/2021 of 13/10/2021 relating to the protection of personal data and privacy, and subject to applicable exceptions, you have the right to:
- Access the personal information we hold about you.
- Correct inaccurate or incomplete personal information.
- Request deletion of your personal information, subject to any legal retention obligations.
- Withdraw consent where processing is based on your consent, without affecting the lawfulness of processing carried out before your withdrawal.
- Object to certain processing of your personal information.
To exercise any of these rights, please contact us using the details in Section 10 below.
6.1 How to Delete Your Account
You can delete your account directly in the app: go to Settings → Delete my account. If you're unable to log in or need assistance, contact us via WhatsApp support or email at contact@smartpaygo.rw, and we will process your deletion request.
7. Children's Privacy
SmartPayGo is not directed at children, and we do not knowingly collect personal information from individuals under the age of 18. If we become aware that we have collected personal information from a child without appropriate consent, we will take steps to delete that information.
8. International Users
SmartPayGo is designed primarily for use in Rwanda. If you access the App from outside Rwanda, please be aware that your information may be processed in Rwanda or in other locations where our service providers operate, which may have different data protection laws than your home country.
9. Changes to This Policy
We may update this Privacy Policy from time to time to reflect changes in our practices or for legal or regulatory reasons. If we make material changes, we will notify you through the App or by other reasonable means before the changes take effect. The "Last updated" date at the top of this policy indicates when it was last revised.
10. Contact Us
If you have questions, concerns, or requests regarding this Privacy Policy or your personal information, please contact us at:
SmartPayGo Ltd
Email: contact@smartpaygo.rw
Website: www.smartpaygo.rw