# Privacy Policy for Kity Pay

**Effective Date:** July 25, 2025  
**Last Updated:** July 25, 2025

## 1. Introduction

Welcome to Kity Pay, a financial application operated by TekJuice. We are committed to protecting your privacy and personal information. This Privacy Policy explains how we collect, use, store, and protect your information when you use our mobile application and services, including digital wallet and cryptocurrency transaction services (USDT and USDC).

**Contact Information:**

- **Company:** Kity Pay
- **Website:** https://kitypay.com/
- **Phone:** +256 773 102176
- **Email:** info@kitipay.com

## 2. Information We Collect

### 2.1 Personal Information

- Full name, address, and contact details
- Email address and phone number (for account creation, recovery, and security notifications)
- Date of birth and identity verification documents (e.g., government-issued ID)
- Financial information, including bank account details and digital wallet addresses
- Transaction history and payment records (including USDT and USDC transactions)
- Know Your Customer (KYC) and Anti-Money Laundering (AML) verification data

### 2.2 Device and Technical Information

- Device identifiers, hardware information, and IP address (for security purposes)
- Operating system and app version
- Location data (when permitted by user settings)
- App usage analytics, performance data, and security logs (to improve services and prevent fraud)

### 2.3 Permissions-Based Information

#### Camera Access

- We request camera permission to enable:
  - Document scanning for identity verification
  - QR code scanning for cryptocurrency transactions (e.g., USDT and USDC)
  - Photo capture for account verification purposes
- Camera access is only used when you actively choose to use these features.

#### Contacts Access

- We request contacts permission to:
  - Facilitate sending money to contacts
  - Enable bill payments to saved payees
  - Improve user experience for recurring transactions
- We do not automatically sync or store your entire contact list without explicit consent.

#### Notification Access

- We use notifications to:
  - Alert you about transaction confirmations (including USDT and USDC transactions)
  - Notify you of account security events
  - Send payment reminders and account updates
  - Provide real-time cryptocurrency price alerts

## 3. How We Use Your Information

### 3.1 Primary Services

- Processing cryptocurrency deposits and withdrawals (including USDT and USDC transactions)
- Facilitating bill payments and mobile money transactions
- Enabling peer-to-peer money transfers
- Maintaining accurate transaction records for security and regulatory compliance

### 3.2 Security and Compliance

- Verifying your identity to prevent fraud and comply with financial regulations
- Monitoring for suspicious activities and protecting against money laundering
- Securing your account, digital wallet, and transactions
- Complying with Anti-Money Laundering (AML) and other regulatory requirements

### 3.3 Communication and Support

- Sending transaction confirmations, receipts, and security alerts
- Providing customer support and assistance
- Delivering important account notifications and product updates
- Sharing security alerts and cryptocurrency-related updates

### 3.4 Service Improvement

- Analyzing app usage to enhance functionality and user experience
- Developing new features and services
- Conducting market research and analytics
- Personalizing your app experience based on usage patterns

## 4. Data Sharing and Disclosure

### 4.1 Third-Party Service Providers

We may share your information with trusted third parties, including:

- Payment processors and cryptocurrency exchanges (for USDT and USDC transactions)
- Identity verification services (KYC partners bound by strict confidentiality agreements)
- Banking partners and financial institutions
- Cloud storage and security providers
- Customer support platforms

*Note:* We do not sell, rent, or share your personal information with third parties for marketing purposes.

### 4.2 Blockchain Networks

- USDT and USDC transactions are processed on public blockchain networks. Transaction details (e.g., wallet addresses and amounts) are recorded on these public ledgers, but we do not share your personal information with these networks.

### 4.3 Legal and Regulatory Requirements

We may disclose your information when required by:

- Financial regulatory authorities
- Law enforcement agencies
- Court orders and legal proceedings
- Anti-money laundering investigations

### 4.4 Business Transfers

In the event of a merger, acquisition, or sale of assets, your information may be transferred to the new entity, subject to the same privacy protections.

## 5. Data Security

### 5.1 Security Measures

- End-to-end encryption for sensitive data (at rest and in transit)
- Multi-factor authentication options
- Regular security audits and monitoring
- Secure data centers with restricted physical and digital access
- Industry-standard security protocols

### 5.2 Financial Data Protection

- PCI DSS compliance for payment processing
- Segregated storage of financial information and digital wallet data
- Real-time fraud detection systems
- Secure API connections with financial partners and blockchain networks

## 6. Data Retention

### 6.1 Active Accounts

- Personal information: Retained while your account is active
- Transaction records: Maintained for regulatory compliance (typically 7 years)
- App usage data: Retained for service improvement purposes

### 6.2 Closed Accounts

- Essential records retained for legal and regulatory requirements
- Non-essential data deleted within 90 days of account closure
- Transaction records (including USDT and USDC) may be retained longer for compliance

## 7. Your Rights and Choices

### 7.1 Access and Control

- View and update your personal information
- Download your transaction history (including cryptocurrency transactions)
- Control notification preferences
- Manage app permissions (camera, contacts, notifications)

### 7.2 Data Protection Rights (Where Applicable)

- Right to access your personal data
- Right to correct inaccurate information
- Right to delete your data (subject to legal requirements)
- Right to restrict processing
- Right to data portability (e.g., export transaction history)

### 7.3 Communication Preferences

- Opt-out of marketing communications
- Customize notification settings
- Control promotional offers and updates

## 8. Cookies and Tracking

We use cookies and similar technologies to:

- Remember your preferences and settings
- Analyze app performance and usage
- Provide personalized content and features
- Ensure security and prevent fraud

You can manage cookie preferences through your device settings.

## 9. Children's Privacy

Kity Pay is not intended for users under 18 years of age. We do not knowingly collect personal information from minors. If we discover that we have collected information from a minor, we will delete it immediately.

## 10. International Data Transfers

Your information may be processed and stored in countries other than your residence to provide our global services. We ensure appropriate safeguards are in place, including:

- Adequacy decisions
- Standard contractual clauses
- Certification schemes

All international transfers comply with applicable privacy laws and maintain high security standards.

## 11. Changes to This Privacy Policy

We may update this Privacy Policy periodically to reflect:

- Changes in our services or business practices
- Updates to legal requirements
- Improvements to our privacy practices

We will notify you of significant changes through:

- In-app notifications
- Email communications
- Updated effective date on this policy

## 12. Contact Us

If you have questions, concerns, or requests regarding this Privacy Policy or your personal information, please contact us:

- **Kity Pay**
- **Website:** https://kitypay.com/
- **Phone:** +256 773 102176
- **Email:** info@kitipay.com

For privacy-specific inquiries, please include "Privacy Policy - Kity Pay" in your subject line.

## 13. Regulatory Compliance

Kity Pay operates in compliance with applicable financial regulations and data protection laws, including but not limited to:

- General Data Protection Regulation (GDPR)
- Payment Services Regulations
- Anti-Money Laundering (AML) directives
- Financial Conduct Authority (FCA) guidelines

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