Privacy Policy

Last Updated: June 7, 2025
Introduction: Zenstack Technologies Ltd (referred to as "we," "us," or "our"), the owner and operator of ZenfiPay, is a technology company based in Lagos, Nigeria, with an upcoming Delaware, USA, corporation. We are the provider of ZenfiPay, a cross-border payment platform that offers seamless money transfer services using email, virtual dollar cards, currency exchange, money sending and requesting, and virtual Naira and foreign bank accounts.

This Privacy Policy explains how Zenstack Technologies Ltd, through its ZenfiPay product, collects, uses, stores, shares, and protects your personal information when you use the ZenfiPay website, mobile application, and services (collectively, the "Platform"). We are committed to protecting your privacy and handling your data with transparency and care.

By accessing or using our Platform, you agree to the collection, use, and disclosure of your information as described in this Privacy Policy. If you do not agree, please do not use our Platform.
1. Information We Collect: We (Zenstack Technologies Ltd, via ZenfiPay) collect various types of information to provide and improve our services, comply with legal obligations, and ensure the security of our Platform.

• Personal Identification Information (PII): This includes your name, email address, phone number, date of birth, nationality, physical address, and government-issued identification documents (e.g., passport, national ID card, driver's license, Bvn, Nin) as required for Know Your Customer (KYC) and Anti-Money Laundering (AML) regulations.

• Financial Information: Details related to your transactions, including bank account numbers, virtual account numbers, card details (last four digits, expiry date, and tokenized data), transaction history (amounts, recipients, dates, currencies), and payment instrument details.

• Transactional Information: Specifics about the transfers, currency swaps, virtual card purchases, and other financial activities you conduct through our Platform, including the purpose of transactions where required.

• Communication Data: Records of your communications with us, including emails, chat transcripts, and customer service calls.

• Technical Data: Information about your device and how you access our Platform, such as your IP address, device type, operating system, browser type, unique device identifiers, mobile network information, and referral URLs.

• Usage Data: Details about your interaction with our Platform, including pages visited, features used, time spent, clickstream data, and performance statistics.

• Cookies and Tracking Technologies: We use cookies and similar technologies (e.g., web beacons, pixels) to collect information about your Browse activities, remember your preferences, enhance your user experience, and for analytics and security purposes. You can manage your cookie preferences through your browser settings.
2. How We Collect Your Information: We (Zenstack Technologies Ltd, via ZenfiPay) collect information in the following ways:

• Directly from You: When you register for an account, complete your profile, initiate transactions, communicate with our customer support, or participate in surveys.

• Automatically: Through your use of our Platform, via cookies, server logs, and other tracking technologies.

• From Third Parties: We may receive information about you from trusted third-party service providers, such as identity verification services, financial institutions, fraud prevention agencies, and public databases, to comply with regulatory requirements and enhance our services.
3. How We Use Your Information: We (Zenstack Technologies Ltd, via ZenfiPay) use the information we collect for various purposes, including:

• To Provide and Maintain Our Services:
• Processing your transfers, currency swaps, and virtual card transactions.
• Managing your virtual Naira bank accounts and foreign accounts.
• Facilitating sending and requesting money.
• Creating and managing your user account.
• Providing customer support and responding to your inquiries.

• For Security and Fraud Prevention:
• Verifying your identity to comply with KYC and AML regulations.
• Detecting, preventing, and investigating fraudulent or unauthorized activities.
• Protecting the security and integrity of our Platform and your account.

• For Communication:
• Sending transaction confirmations, service announcements, and administrative messages.
• Providing updates about our services, promotions, and offers (you can opt out of marketing communications).
• Responding to your questions and feedback.

• For Improvement and Personalization:
• Analyzing usage patterns to understand how our Platform is used and to improve its functionality, features, and user experience.
• Personalizing your experience on the Platform.

• For Legal and Regulatory Compliance:
• Complying with applicable laws, regulations, legal processes, and government requests in Nigeria, the USA, and other relevant jurisdictions.
• Enforcing our Terms and Conditions.
4. How We Share Your Information: We (Zenstack Technologies Ltd, via ZenfiPay) do not sell your personal information. We may share your information with third parties only in the following circumstances:

• With Service Providers: We engage trusted third-party companies and individuals to perform services on our behalf, such as payment processing, identity verification, cloud hosting, data analytics, customer support, and marketing. These service providers are contractually obligated to protect your information and use it only for the purposes for which it was disclosed.

• For Legal and Regulatory Reasons: We may disclose your information if required to do so by law, in response to valid requests by public authorities (e.g., court order, subpoena), or to comply with AML/CFT obligations. We may also disclose information to protect Zenstack Technologies Ltd's rights, property, or safety, or that of our users or the public.

• In Case of Business Transfer: In the event of a merger, acquisition, restructuring, or sale of all or a portion of Zenstack Technologies Ltd's assets, including the ZenfiPay product, your information may be transferred as part of that transaction. We will notify you via email and/or a prominent notice on our Platform of any such change in ownership or control of your personal information.

• With Your Consent: We may share your information with third parties for any other purpose only with your explicit consent.
5. International Data Transfers: Given our cross-border operations and upcoming Delaware incorporation, your information may be stored and processed in countries outside of Nigeria, including the United States, where data protection laws may differ from those in your home country. When we transfer your information internationally, we implement appropriate safeguards to ensure your data remains protected in accordance with this Privacy Policy and applicable laws.
6. Data Security: We (Zenstack Technologies Ltd, via ZenfiPay) implement robust technical and organizational security measures to protect your personal information from unauthorized access, alteration, disclosure, or destruction. These measures include data encryption, secure server infrastructure, access controls, firewalls, regular security audits, and employee training. While we strive to protect your data, no method of transmission over the internet or electronic storage is 100% secure. Therefore, we cannot guarantee its absolute security.
7. Data Retention: We (Zenstack Technologies Ltd, via ZenfiPay) retain your personal information for as long as necessary to provide our services, comply with our legal and regulatory obligations (e.g., AML laws require us to retain certain transaction data for a specified period), resolve disputes, and enforce our agreements. Once your data is no longer required for these purposes, we will securely delete or anonymize it.
8. Your Privacy Rights: You have certain rights regarding your personal information, subject to applicable laws and regulations:

• Right to Access: You have the right to request access to the personal information we hold about you.

• Right to Rectification: You have the right to request that we correct any inaccurate or incomplete personal information.

• Right to Erasure (Right to be Forgotten): You may request the deletion of your personal information, though this right is subject to our legal and regulatory obligations (e.g., we may be required to retain certain data for AML compliance).

• Right to Restriction of Processing: You have the right to request that we restrict the processing of your personal information in certain circumstances.

• Right to Data Portability: You have the right to receive your personal information in a structured, commonly used, and machine-readable format.

• Right to Object to Processing: You have the right to object to the processing of your personal information for direct marketing purposes or certain other processing activities.

• Right to Withdraw Consent: Where processing is based on your consent, you have the right to withdraw your consent at any time.

To exercise any of these rights, please contact us using the details provided in the "Contact Us" section below. We will respond to your request in accordance with applicable laws.
9. Third-Party Links: Our Platform may contain links to third-party websites or services that are not operated by us. This Privacy Policy does not apply to such third-party services. We encourage you to review the privacy policies of any third-party sites you visit.
10. Children's Privacy: Our services are not directed to individuals under the age of 18. We do not knowingly collect personal information from children. If we become aware that we have collected personal information from a child without parental consent, we will take steps to remove that information from our servers.
11. Changes to This Privacy Policy: We may update this Privacy Policy from time to time to reflect changes in our practices, technology, legal requirements, or other factors. We will notify you of any material changes by posting the new Privacy Policy on this page and updating the "Last Updated" date. We may also notify you via email or through a prominent notice on our Platform prior to the change becoming effective. Your continued use of the Platform after the effective date of the revised Privacy Policy constitutes your acceptance of the changes.
12. Contact Us: If you have any questions about this Privacy Policy, our data practices, or if you wish to exercise your privacy rights, please contact us:

Email: compliance@zenfipay.com