Privacy policy

1Who we are

[Nomapay legal entity name, company number and registered address] is responsible for your personal data. Our data protection contact is [data protection officer name and email]. This policy covers the Nomapay app and this website, separately.

2Data the app uses

• Account: your phone number, your name, and the public half of your passkey. Sign-in codes (sent by SMS or WhatsApp) are stored only in scrambled form, and expire after 10 minutes.
• Payments: what you send and receive, to whom and when, so we can show your activity and statuses and keep your account safe.
• Identity checks: only when you need higher limits or services such as cash-out (see below).
• Device and safety: sign-ins and new devices, so we can alert you and apply the safety window.
• Support: what you tell us when you contact us.

We use this data to provide the service, to keep your account and others safe, to meet legal duties (for example on fraud and money laundering), and to answer you. We never sell personal data.

3Identity checks (KYC)

When you raise your identity level, we collect a government ID number, and for the highest level an ID document and a selfie. These checks are carried out for us by identity-verification providers, and the payment partners that process cash-outs may need to verify you too. They only use your data to check your identity and meet their legal duties. [Counsel: list of provider categories and their roles (processor or controller)]

4Data this website uses

• Waitlist: if you join, your phone number, country, optional email and your choices. We only use it to tell you about Nomapay, never share it, and never reveal whether a number is on the list.
• Pay links: the phone number in a /to/ link is shown back to you on the page, and is never stored by this website or sent to analytics.
• Analytics: none today. If we add it, it will be privacy-friendly counts of visits. Never phone numbers, emails, names or query strings. See the cookie policy.
• Server logs: standard technical logs for security, kept for [log retention period].

5International transfers

Our services and providers may process data outside the country you live in, including [countries / regions]. When they do, we use the safeguards the law requires, such as contract clauses approved for that purpose. [Counsel: transfer mechanisms under each law]

6Your rights

Wherever you live, you can ask to see the data we hold about you, to correct it, to delete it where the law allows, to object to or restrict some uses, and to take a copy with you. You can withdraw consent at any time. Write to us to use any of these rights.

7How long we keep data

• Account and payment records: for as long as you have an account, then [period required by law].
• Identity check results: [period required by anti-money-laundering law].
• Waitlist entries: until launch, or until you ask us to remove yours.
• Support messages: [period].

Some records about payments are written to public networks by design and cannot be deleted by anyone. They do not contain your name or phone number.

8Contact

Write to [privacy email] or support@nomapay.co. We will reply within [response time required by law].