1. General

1.1 Our Privacy Policy
We are committed to protecting your information and respecting your privacy.

This Privacy Policy together with the KuulPay Terms of Use set out the basis on which any personal data we collect from you, or which you provide us, through our website during registration or after will be processed by us.

When you complete any form, speak with our staff or submit any details to us, we will collect, use and disclose your personal information as described in this Privacy Policy.

Please read this Privacy Policy carefully to understand our practices regarding your personal data, how we use it and how we will treat it. If you do not agree with this Privacy Policy, please do not use our services.

1.2 Changes to this Privacy Policy
Any changes we make to this Privacy Policy in the future will be posted on this page. We reserve the right to make changes to this to our Privacy Policy at any time, without notice, where such change is required by application legislation

2. Information We Collect

2.1 Information We Collect from You
We may collect and process the following data about you:

* your full name, address, email address, telephone number, date of birth and proof of your identity and/or address that we may request,

* details of any transactions you carry out through our website using your KuulPay Account,

*information collected through cookies,

*your IP address, log-in times, operating system and browser type.

2.2 Information We Collect from Third Parties about You
In order to fulfil our legal obligations to prevent fraud and money laundering, we will obtain information about you from third party agencies, including your financial history, country court judgements and bankruptcies, from credit reference and fraud prevention agencies at any time we feel it is necessary to prevent fraud and minimise our financial risks.

3. How We Use Your Information

We use information about you in the following ways:
* to operate and administer your KuulPay Account and to provide services that you have requested,
* to carry out your instructions to make and receive payments and undertake transactions using our services
* to allow you to participate in interactive features of the Website,
* to notify you about changes to our services(s),
* to improve our internal customer training,
* to comply with financial services regulations including retention of financial information and transactions,
* for financial and identity checks, fraud prevention checks, anti-money laundering,
* for customer service, including answering questions and responding to feedback and complaints,
* to enhance the security of our services,
* to ensure that content on our Website is presented in the most effective manner for you and your computer,
* to provide you with information, products or services that you request from us or which we feel may interest you.

4. Storing Your Personal Data

4.1 Where is it Stored?
The data we collect from you is store or process in accordance with our internal operational requirements and procedures in order to administer the services you require or in connection with anti-fraud measures.

4.2 Security
We are committed to ensuring that your information is secure. To prevent unauthorised access or disclosure of your information, we have physical, electronic and managerial procedures in place to keep your information sage. Once logged into your KuulPay account, all internet communication is secured using Secure Socket Layer(SSL) technology with high security 128bit encryption, certified by Verising Secured.

However, you must never share your KuulPay Account or login details with anyone. If you fear any of your login details have been compromised, you can change them any time once you are logged on.

Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our site. Any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.

4.3 Retention
We are by law required to retain certain records for a period of at least five years after closure of your KuulPay Account which will include your personal data such as your name, contact details, customer number and transaction history etc. Otherwise, we will delete and destroy all personal data that we hold about you when you(or we) terminate your KuulPay Account.

5. Disclosure of Your Information

5.1 Merchants and other KuulPay Customers
When sending money to another KuulPay Account holder or a merchant who wish to pay, we will, at a minimum, pass on your email address and name to the recipient.

5.2 Fraud and Credit Reference Agencies
We may share certain information about you and your KuulPay Account, financial history and transactions as part of our normal business operations with our banks, payment facilitator partners, identity verification service providers and credit reference agencies to identify and verify users, to limit our exposure to fraud and other criminal activities and to manage our financial risk.

5.3 Other Disclosures
We will share your personal information with third parties only in the ways that are described in this Privacy Policy. We do not sell your personal information to third parties. We may however disclose your personal information to:

* a prospective buyer of our business or a buyer of a substantial number of the shares in our business, if KuulPay is involved in a merger, acquisition, or sale of all or a portion of its assest.

* the police, other lawful enforcement body, regulatory body or court if we are under a duty or required by law to disclose or share your personal data, or to protect the rights, property, or safety of ourselves or our customers, or others

6. Cookies

A cookie is a small amount of data which contains information that is downloaded to the device from which you access our site.

Cookies are usefull because they allow us and other websites to recognise your device.

We use cookies to make our website work more efficiently, as well as to provide information to us.

When you visit a page on our site with content embedded from third parties, for example, YouTube or Twitter, cookies may be downloaded onto your device. We do not set or control these cookies.