Privacy Policy

AzariPay Technologies Ltd. Privacy Policy

Introduction

Welcome to AzariPay Technologies Ltd (“AzariPay“, “we“, “our“, or “us“).

At AzariPay, protecting your privacy and safeguarding your personal information are fundamental to the trust you place in us. We are committed to collecting, processing, storing, using, and protecting your personal data responsibly, transparently, and in accordance with applicable data protection, financial services, and cybersecurity laws.

This Privacy Policy explains how AzariPay collects, uses, shares, stores, retains, and protects your personal information whenever you use our products and services, including but not limited to:

• The AzariPay Mobile Application;
• The AzariPay Website;
• AzariPay Digital Wallet;
• Cross-Border Payment Services;
• Global Accounts;
• Business Banking Services;
• Foreign Exchange Services;
• Debit, Credit and Virtual Card Services;
• Merchant and Business Solutions;
• Azari Select premium lifestyle and concierge services;
• APIs and developer services; and
• Any other products, services, websites, platforms, applications, or digital channels owned, operated, or provided by AzariPay Technologies Ltd.

This Privacy Policy also describes your privacy rights, the choices available to you regarding your personal information, and the measures we implement to maintain the confidentiality, integrity, and security of your data.

By opening an account, accessing our website, downloading or using our mobile application, or otherwise using any AzariPay product or service, you acknowledge that you have read, understood, and agree to the collection, processing, storage, disclosure, and use of your personal information as described in this Privacy Policy.

Where your consent is required by applicable law, we will obtain it before processing your personal information. In other circumstances, we may process your information where necessary to provide our services, comply with legal and regulatory obligations, prevent fraud, protect the security of our platform, enforce our contractual rights, or pursue our legitimate business interests.

Your privacy is important to us, and we continuously review and improve our privacy practices, information security controls, and governance framework to ensure that your personal information remains protected while enabling us to deliver secure, innovative, and reliable financial services across Nigeria and internationally.

Scope of this Privacy Policy

This Privacy Policy applies to all personal information collected, received, generated, processed, stored, shared, or otherwise handled by AzariPay Technologies Ltd (“AzariPay“, “we“, “our“, or “us“) in connection with the provision of our products, services, platforms, and business operations.

This Policy applies to all individuals and organisations that interact with AzariPay, including but not limited to:

• Individual customers and wallet holders;
• Prospective customers and account applicants;
• Business customers, merchants, corporate clients, and their authorised representatives;
• Visitors to the AzariPay website and mobile applications;
• Users of AzariPay APIs, developer platforms, and digital services;
• Beneficiaries, recipients, and counterparties involved in transactions processed through AzariPay;
• Participants in Azari Select, loyalty programmes, promotional campaigns, referral programmes, and concierge services;
• Vendors, contractors, consultants, service providers, and business partners where personal data is processed in connection with our business relationship;
• Job applicants and individuals participating in AzariPay recruitment processes; and
• Any other person whose personal information is processed by AzariPay in the course of providing our services or conducting our legitimate business activities.

This Privacy Policy governs personal information collected through, including but not limited to:

• The AzariPay website and related web portals;
• The AzariPay mobile application;
• Digital wallet services;
• Cross-border payment services;
• Foreign exchange services;
• Global account services;
• Business banking solutions;
• Card products and payment services;
• Merchant services and payment gateways;
• Customer support channels, including telephone, email, live chat, social media, messaging platforms, and physical offices;
• Marketing campaigns, surveys, events, promotions, and competitions; and
• Any other digital or physical channel through which AzariPay provides products or services.

This Policy applies regardless of the technology or device used to access our services, including mobile phones, tablets, computers, point-of-sale devices, application programming interfaces (APIs), and other connected technologies.

This Privacy Policy applies to personal information processed within Nigeria and, where applicable, to information processed in other countries in connection with AzariPay’s international operations, cross-border payment services, global partnerships, and foreign subsidiaries or affiliates. Where local laws impose additional privacy or data protection requirements, AzariPay will comply with those requirements to the extent applicable.

This Privacy Policy does not apply to:

• Websites, applications, or services owned or operated by third parties that may be linked to or integrated with AzariPay’s services;
• Products or services provided solely by independent third parties, even where such services are accessible through the AzariPay platform; or
• Information that has been irreversibly anonymised so that it can no longer reasonably identify an individual.

Users are encouraged to review the privacy policies of third-party websites, applications, financial institutions, merchants, and service providers before providing personal information to them, as AzariPay is not responsible for the privacy practices, security measures, or content of third-party services that it does not own or control.

Nothing in this Privacy Policy limits AzariPay’s obligations under applicable data protection, financial services, anti-money laundering, counter-terrorist financing, sanctions, cybersecurity, consumer protection, or other applicable laws and regulations. Where there is any inconsistency between this Policy and mandatory legal or regulatory requirements, the applicable law or regulation shall prevail.

Definitions

For the purposes of this Privacy Policy, the following terms shall have the meanings set out below unless the context requires otherwise.

“Account”

Any AzariPay wallet, digital account, merchant account, business account, global account, card account, or any other account opened or maintained with AzariPay.

“Affiliate”

Any company, subsidiary, parent company, joint venture, representative office, or other entity that directly or indirectly controls, is controlled by, or is under common control with AzariPay Technologies Ltd.

“Anonymous Data”

Information that has been permanently de-identified or aggregated so that it cannot reasonably be used to identify an individual.

“Applicable Law”

Any law, regulation, guideline, directive, regulatory requirement, judicial decision, or governmental order applicable to AzariPay or the processing of Personal Data, including data protection, financial services, anti-money laundering, counter-terrorism financing, sanctions, cybersecurity, and consumer protection laws.

“AzariPay”

Refers to AzariPay Technologies Ltd, its subsidiaries, affiliates, successors, assigns, employees, authorised representatives, agents, contractors, and service providers acting on its behalf.

“Biometric Data”

Personal information relating to an individual’s unique biological characteristics, including facial images, fingerprints, voice recognition data, or other biometric identifiers collected for identity verification, fraud prevention, security, or regulatory compliance.

“Business Customer”

Any company, organisation, partnership, sole proprietorship, government entity, non-profit organisation, or other legal person using AzariPay’s products or services.

“Consent”

Any freely given, specific, informed, and unambiguous indication by which a Data Subject signifies agreement to the processing of Personal Data.

“Cookies”

Small text files or similar technologies stored on a user’s device to enhance functionality, improve user experience, analyse usage, personalise services, and maintain security.

“Cross-Border Transfer”

The transfer, storage, access, or processing of Personal Data outside the country in which it was originally collected.

“Data Controller”

The natural or legal person who determines the purposes and means of processing Personal Data. Unless otherwise stated, AzariPay acts as the Data Controller for Personal Data processed under this Privacy Policy.

“Data Processor”

A natural or legal person who processes Personal Data on behalf of a Data Controller.

“Data Subject”

Any identified or identifiable natural person whose Personal Data is processed by AzariPay.

“Device Information”

Information collected from devices used to access AzariPay services, including device identifiers, operating system, browser type, IP address, mobile network information, device model, security settings, and usage information.

“KYC (Know Your Customer)”

The customer identification and verification procedures required by applicable laws and regulations before or during the provision of financial services.

“Personal Data” or “Personal Information”

Any information relating to an identified or identifiable individual, whether directly or indirectly, including but not limited to names, addresses, email addresses, telephone numbers, dates of birth, identification numbers, financial information, transaction history, photographs, biometric information, location data, online identifiers, and any other information capable of identifying an individual.

“Processing”

Any operation performed on Personal Data, whether automated or manual, including collection, recording, organisation, storage, adaptation, retrieval, consultation, use, disclosure, transmission, sharing, analysis, combination, restriction, anonymisation, deletion, destruction, or any other handling of Personal Data.

“Sensitive Personal Data”

Personal Data that requires enhanced protection under applicable law, including biometric information, financial account information, government-issued identification details, authentication credentials, and any other category designated as sensitive by applicable law.

“Services”

All products, platforms, applications, websites, APIs, payment services, card products, merchant solutions, cross-border payment services, global accounts, foreign exchange services, business banking services, concierge offerings, and any other products or services provided by AzariPay.

“Third Party”

Any individual, organisation, financial institution, payment network, merchant, technology provider, regulator, government authority, law enforcement agency, contractor, vendor, or other entity that is not the Data Subject or AzariPay.

“Transaction Data”

Information relating to payments, transfers, deposits, withdrawals, exchanges, card usage, merchant transactions, account balances, payment instructions, recipients, timestamps, currencies, and other financial activities conducted through AzariPay.

“User”, “Customer”, or “You”

Any individual or organisation that accesses, registers for, uses, or attempts to use any AzariPay product, service, website, mobile application, or platform.

Interpretation

Unless the context otherwise requires:

• Words importing the singular include the plural and vice versa.
• References to one gender include all genders.
• References to “including” or “includes” mean “including without limitation.”
• Section headings are for convenience only and do not affect interpretation.
• References to laws or regulations include any amendments, replacements, or successor legislation.

Information We Collect

To provide secure, reliable, and compliant financial services, AzariPay Technologies Ltd (“AzariPay“, “we“, “our“, or “us“) collects, receives, generates, and processes various categories of personal and business information. The information we collect depends on the products and services you use, your interactions with us, and our legal and regulatory obligations.

1. Information You Provide Directly

When you register for or use AzariPay services, we may collect information that you voluntarily provide, including:

• Full name;
• Residential, business, and mailing addresses;
• Date and place of birth;
• Gender (where required);
• Nationality and country of residence;
• Mobile telephone number(s);
• Email address(es);
• Username and account credentials;
• Government-issued identification details (such as National Identification Number (NIN), international passport, driver’s licence, voter card, residence permit, or other legally accepted identification documents);
• Bank Verification Number (BVN), National Identification Number (NIN), Tax Identification Number (TIN), or similar identifiers where required by law;
• Passport photographs, selfies, live facial verification images, and other identity verification records;
• Signature (electronic or handwritten);
• Occupation, employer, source of income, and employment information;
• Business registration documents for merchants and corporate customers;
• Payment instructions and beneficiary details; and
• Any other information you choose to provide to us.

2. Identity Verification (KYC) Information

To comply with applicable Know Your Customer (KYC), Anti-Money Laundering (AML), Counter-Terrorism Financing (CTF), sanctions, fraud prevention, and financial crime regulations, AzariPay may collect and verify:

• Identity documents;
• Facial verification images and liveness checks;
• Biometric verification information where legally permitted;
• Proof of residential address;
• Utility bills and supporting documentation;
• Source of funds and source of wealth information;
• Politically Exposed Person (PEP) declarations;
• Beneficial ownership information;
• Company ownership and control information; and
• Any additional documentation required by regulators or our compliance procedures.

3. Financial and Transaction Information

When you use AzariPay, we collect information relating to your financial activities, including:

• Wallet balances;
• Deposits and withdrawals;
• Local and international transfers;
• Merchant payments;
• Card transactions;
• Foreign exchange transactions;
• Bill payments;
• Airtime and data purchases;
• Payment references;
• Transaction dates and times;
• Currency information;
• Transaction status;
• Recipient and sender information;
• Charges and fees;
• Account funding sources; and
• Other payment-related records required for transaction processing and audit purposes.

4. Device and Technical Information

When you access our website, mobile application, or other digital platforms, we may automatically collect technical information, including:

• IP address;
• Device identifiers;
• Device model and manufacturer;
• Operating system and version;
• Browser type and version;
• Mobile network information;
• Application version;
• Language preferences;
• Time zone settings;
• Device security status;
• Log files;
• Crash reports;
• Performance diagnostics; and
• Session identifiers.

5. Location Information

Where permitted by law and with your permission where required, AzariPay may collect:

• GPS location;
• Approximate location based on IP address;
• Country and city;
• Transaction location; and
• Device location used for fraud prevention, account security, regulatory compliance, and service enhancement.

You may disable certain location permissions through your device settings; however, some services or security features may become unavailable or limited.

6. Usage Information

We may collect information about how you use our services, including:

• Login history;
• Authentication attempts;
• Navigation behaviour;
• Pages viewed;
• Features accessed;
• Search queries;
• Time spent using our services;
• Customer preferences;
• Interaction with notifications;
• Referral information; and
• Customer support interactions.

7. Communications

When you communicate with AzariPay, we may collect and retain:

• Emails;
• Live chat conversations;
• Customer support tickets;
• Telephone call recordings where permitted by law;
• SMS messages;
• Social media interactions;
• Survey responses;
• Feedback and complaints; and
• Communications relating to disputes, investigations, or regulatory matters.

8. Information from Third Parties

We may receive information from trusted third parties, including:

• Identity verification providers;
• Financial institutions;
• Payment networks;
• Card schemes;
• Credit reference agencies;
• Fraud prevention databases;
• Government agencies;
• Regulatory authorities;
• Law enforcement agencies where legally authorised;
• Publicly available records;
• Merchants and business partners;
• Marketing partners; and
• Other service providers that support the delivery of our services.

9. Cookies and Similar Technologies

Our website, mobile applications, and digital platforms may use cookies, pixels, SDKs, web beacons, and similar technologies to:

• Authenticate users;
• Maintain secure sessions;
• Improve website functionality;
• Analyse website performance;
• Understand user behaviour;
• Detect fraud;
• Personalise user experiences; and
• Enhance security.

Additional information about our use of cookies may be provided in our Cookie Policy.

10. Information Generated Through Your Use of Our Services

AzariPay may generate information based on your interactions with our services, including:

• Risk scores;
• Fraud detection indicators;
• Security alerts;
• Customer service history;
• Account activity summaries;
• Transaction patterns;
• Loyalty programme participation;
• Azari Select membership activity;
• Concierge service requests;
• Creditworthiness or eligibility assessments where applicable; and
• Other internally generated records necessary for the operation, security, and improvement of our services.

11. Information We Are Required to Collect

Certain information is collected because we are legally or contractually required to do so. Failure to provide required information may prevent us from opening your account, processing transactions, complying with regulatory obligations, or continuing to provide certain products or services.

12. Accuracy of Information

You are responsible for ensuring that all information provided to AzariPay is accurate, complete, and up to date. You agree to promptly notify us of any changes to your personal or business information. AzariPay may request updated information or supporting documentation at any time to comply with legal, regulatory, security, or operational requirements.

KYC & Identity Verification

1. Our Commitment to Identity Verification

As a financial technology company, AzariPay Technologies Ltd (“AzariPay“, “we“, “our“, or “us“) is committed to maintaining a secure, trusted, and compliant financial ecosystem. To protect our customers, partners, and the integrity of our platform, we conduct Know Your Customer (“KYC”), Customer Due Diligence (“CDD”), Enhanced Due Diligence (“EDD”), and identity verification procedures in accordance with applicable laws, regulations, and industry standards.

Identity verification helps us prevent fraud, identity theft, money laundering, terrorist financing, sanctions evasion, cybercrime, financial crime, and other unlawful activities.

2. Information We May Collect for KYC

To establish and verify your identity, we may collect and process one or more of the following:

• Full legal name;
• Date and place of birth;
• Nationality and country of residence;
• Residential, business, and mailing addresses;
• Mobile telephone number(s);
• Email address(es);
• Government-issued identification documents, including National Identification Number (NIN), Bank Verification Number (BVN), passport, driver’s licence, voter’s card, residence permit, tax identification number (TIN), or any other identification recognised by applicable law;
• Passport photographs, selfies, live facial images, or video verification;
• Biometric information, where permitted by law;
• Proof of address, including utility bills, bank statements, tenancy documents, or other acceptable evidence;
• Occupation, employer, profession, and employment details;
• Source of income, source of funds, and source of wealth information;
• Politically Exposed Person (PEP) status and related declarations;
• Beneficial ownership information for corporate or business customers;
• Corporate registration documents, licences, tax records, and authorised signatory information; and
• Any additional documentation reasonably required to satisfy legal, regulatory, security, or operational requirements.

3. Verification Methods

AzariPay may verify your identity using one or more methods, including:

• Validation against government or authorised identity databases;
• Electronic KYC (e-KYC) services;
• Facial recognition and liveness detection technologies;
• Biometric verification where legally permitted;
• Verification through licensed third-party identity verification providers;
• Bank account verification;
• Mobile number verification;
• Address verification;
• Documentary verification;
• Video or live verification interviews;
• Corporate registry searches;
• Credit bureau or authorised reference checks where applicable; and
• Any other lawful verification process deemed appropriate by AzariPay.

4. Ongoing Customer Due Diligence

Identity verification is not a one-time exercise. To comply with applicable laws and to safeguard our platform, AzariPay may conduct ongoing reviews of customer information throughout the duration of the business relationship. This may include:

• Periodic KYC refreshes;
• Requests for updated identification documents;
• Verification of changes to personal or business information;
• Monitoring of transaction patterns;
• Risk reassessments;
• Enhanced due diligence for higher-risk customers or transactions; and
• Additional verification where suspicious, unusual, or potentially unlawful activity is identified.

You agree to cooperate promptly with any request for updated information or documentation. Failure to do so may result in restrictions, suspension, or closure of your account.

5. Screening Against Watchlists

Where required or permitted by law, AzariPay may screen customers, authorised representatives, beneficial owners, counterparties, and transactions against:

• International sanctions lists;
• Anti-money laundering databases;
• Counter-terrorism financing databases;
• Politically Exposed Person (PEP) databases;
• Adverse media databases;
• Fraud prevention databases;
• Regulatory enforcement lists; and
• Other legally recognised screening systems.

Such screening may occur before account opening, during the customer relationship, and whenever transactions are processed.

6. Information Obtained from Third Parties

To verify your identity and meet our legal obligations, AzariPay may obtain information from:

• Government agencies;
• Financial institutions;
• Identity verification service providers;
• Credit reference agencies, where permitted;
• Regulatory authorities;
• Publicly available records;
• Corporate registries;
• Payment partners; and
• Other trusted third-party data sources authorised by law.

7. Failure to Complete Verification

Where you fail or refuse to provide requested information or documentation, or where we are unable to verify your identity to our reasonable satisfaction, AzariPay reserves the right to:

• Decline your application;
• Delay or refuse account activation;
• Restrict access to certain products or services;
• Suspend or limit transactions;
• Reject or reverse transactions where legally permitted;
• Freeze or place temporary holds on accounts where required by law;
• Terminate the customer relationship; and
• Report suspicious activities to competent regulatory or law enforcement authorities where required by applicable law.

8. Accuracy of Information

You represent and warrant that all information and documentation provided to AzariPay for identity verification purposes is true, accurate, complete, current, and not misleading. You agree to notify AzariPay promptly of any changes to your personal or business information and to provide updated documentation upon request.

Providing false, fraudulent, altered, forged, or misleading information may result in account suspension or termination, refusal of services, recovery of losses where legally permissible, and reporting to the appropriate authorities.

9. Protection of KYC Information

AzariPay implements appropriate technical, organisational, and administrative safeguards to protect KYC and identity verification information from unauthorised access, disclosure, alteration, loss, or misuse. Access to such information is restricted to authorised personnel and trusted service providers who require it to perform their duties and are subject to appropriate confidentiality and security obligations.

10. Customer Consent

By applying for or maintaining an account with AzariPay, you acknowledge and expressly authorise AzariPay to collect, verify, process, store, update, and share your identity verification information with authorised service providers, financial institutions, regulators, government agencies, and other third parties where necessary to provide our services, comply with legal and regulatory obligations, prevent fraud and financial crime, protect the security and integrity of our platform, or enforce our contractual and legal rights. Such processing will be carried out in accordance with applicable data protection laws and this Privacy Policy.

Transaction Information

1. Collection of Transaction Information

To provide secure, efficient, and reliable financial services, AzariPay Technologies Ltd (“AzariPay“, “we“, “our“, or “us“) collects, records, processes, stores, and analyses information relating to transactions conducted through our platforms and services.

Transaction information is collected to facilitate payment processing, maintain accurate financial records, comply with legal and regulatory obligations, prevent fraud, resolve disputes, improve our services, and protect the integrity of the AzariPay ecosystem.

2. Types of Transaction Information We Collect

Depending on the services you use, we may collect and process:

• Wallet funding and withdrawal records;
• Local and international money transfers;
• Incoming and outgoing payments;
• Merchant and business payment records;
• Card transactions, including debit, credit, virtual, and prepaid card activity;
• Foreign exchange transactions;
• Cross-border payment information;
• Bill payments;
• Airtime and data purchases;
• QR code and contactless payment transactions;
• Payment requests and payment links;
• Standing instructions and recurring payments;
• Refunds, reversals, chargebacks, and disputes;
• Investment, savings, lending, or other financial product transactions where applicable;
• Concierge or premium service payments through Azari Select;
• Transaction references and unique identifiers; and
• Any other financial transaction processed through AzariPay.

3. Transaction Details

For each transaction, AzariPay may collect and retain information including:

• Date and time of the transaction;
• Transaction amount;
• Currency used;
• Exchange rate, where applicable;
• Sender and recipient details;
• Wallet or account identifiers;
• Merchant information;
• Payment method;
• Payment channel;
• Bank or financial institution involved;
• Card network or payment scheme details;
• Transaction description or narration;
• Transaction status;
• Authorisation and authentication records;
• Device information used to initiate the transaction;
• IP address and approximate transaction location where appropriate;
• Applicable fees, commissions, taxes, and charges; and
• Any supporting information necessary to complete, verify, or investigate the transaction.

4. Purpose of Processing Transaction Information

AzariPay processes transaction information to:

• Execute and settle payment instructions;
• Facilitate domestic and international transfers;
• Process foreign exchange transactions;
• Verify customer instructions;
• Detect, prevent, and investigate fraud, money laundering, terrorist financing, sanctions violations, and other financial crimes;
• Conduct risk assessments and transaction monitoring;
• Maintain transaction histories and account statements;
• Provide customer support and resolve complaints;
• Comply with legal, regulatory, accounting, taxation, and audit requirements;
• Improve our products, services, and customer experience;
• Generate anonymised statistical and operational reports; and
• Protect the rights, property, security, and legitimate interests of AzariPay, our customers, and third parties.

5. Transaction Monitoring

To safeguard our platform and comply with applicable laws, AzariPay continuously monitors transactions using automated systems and, where appropriate, manual review processes. Monitoring may include:

• Detection of unusual or suspicious transaction patterns;
• Fraud prevention and risk scoring;
• Anti-Money Laundering (AML) monitoring;
• Counter-Terrorist Financing (CTF) monitoring;
• Sanctions screening;
• Duplicate transaction detection;
• Velocity and behavioural analysis;
• Device and account security monitoring; and
• Other lawful monitoring activities designed to protect customers and the financial system.

Where necessary, transactions may be delayed, declined, reversed, restricted, or reported to competent authorities in accordance with applicable law.

6. Sharing of Transaction Information

AzariPay may disclose transaction information where necessary to:

• Banks and other financial institutions;
• Payment processors and payment networks;
• Card schemes;
• Correspondent banking partners;
• Foreign exchange providers;
• Merchants and beneficiaries involved in a transaction;
• Identity verification and fraud prevention service providers;
• Regulatory authorities;
• Tax authorities;
• Law enforcement agencies;
• Courts and tribunals;
• Auditors and professional advisers; and
• Other third parties where disclosure is authorised by law, required to provide our services, or made with your consent.

We do not sell your transaction information to third parties.

7. Transaction Records and Retention

AzariPay retains transaction records for as long as necessary to:

• Maintain accurate financial records;
• Comply with applicable legal and regulatory obligations;
• Support dispute resolution and investigations;
• Meet audit, accounting, and taxation requirements;
• Enforce our contractual rights; and
• Protect the security and integrity of our services.

Transaction records may continue to be retained after an account has been closed where required by law or where reasonably necessary to protect AzariPay’s legitimate interests.

8. Accuracy of Transaction Information

Customers are responsible for ensuring that payment instructions, recipient details, account information, and transaction data submitted to AzariPay are accurate and complete before authorising a transaction.

AzariPay is not responsible for delays, failed transactions, or losses arising from inaccurate, incomplete, outdated, or incorrect information provided by a customer, except where such liability cannot be excluded under applicable law.

9. Customer Authorisation

By initiating or authorising a transaction through AzariPay, you expressly authorise AzariPay to collect, process, store, analyse, verify, transmit, and disclose transaction information as reasonably necessary to execute your instructions, comply with applicable laws and regulatory requirements, prevent fraud and financial crime, protect the security of our services, resolve disputes, and fulfil our contractual obligations.

10. Use of Aggregated and Anonymised Transaction Data

AzariPay may aggregate, anonymise, or de-identify transaction information so that it no longer identifies any individual. Such anonymised information may be used for:

• Product development and innovation;
• Service improvement;
• Market and business intelligence;
• Statistical analysis;
• Operational planning;
• Risk management;
• Regulatory reporting; and
• Academic or industry research,

provided that the information cannot reasonably be used to identify any individual customer.

Device & Technical Information

1. Collection of Device and Technical Information

When you access or use any AzariPay product, service, website, mobile application, API, or digital platform, AzariPay Technologies Ltd (“AzariPay“, “we“, “our“, or “us“) may automatically collect certain device and technical information to ensure the security, functionality, performance, and reliability of our services.

This information helps us authenticate users, detect fraud, improve user experience, troubleshoot technical issues, monitor system performance, comply with legal and regulatory obligations, and protect the integrity of our platforms.

2. Types of Device and Technical Information We Collect

Depending on the device and services you use, we may collect:

Device Information

• Device model and manufacturer;
• Device type;
• Operating system and version;
• Device identifiers (including Android ID, device token, or other unique identifiers);
• Mobile network operator;
• SIM country and network information;
• Device language and regional settings;
• Screen resolution and display settings;
• Battery status where necessary for application performance; and
• Time zone settings.

Network Information

• Internet Protocol (IP) address;
• Internet Service Provider (ISP);
• Connection type (Wi-Fi, mobile data, broadband, etc.);
• Network performance information;
• Browser configuration; and
• Network diagnostic information.

Application Information

• AzariPay application version;
• Installation date;
• Update history;
• Application usage statistics;
• Application performance information;
• Error logs;
• Crash reports;
• Session identifiers; and
• Authentication status.

Browser Information

Where you access our services through a web browser, we may collect:

• Browser type;
• Browser version;
• Browser language;
• Operating platform;
• Referring and exit pages;
• Date and time of access;
• Website navigation information; and
• Cookie and session identifiers.

3. Security and Authentication Information

To protect your account and our systems, we may collect information relating to security and authentication, including:

• Login history;
• Login timestamps;
• Failed login attempts;
• Password reset requests;
• Multi-factor authentication records;
• One-Time Password (OTP) verification records;
• Device recognition information;
• Trusted device registration;
• Security alerts;
• Fraud detection indicators;
• Risk scores generated by our security systems; and
• Other authentication-related information necessary to protect your account.

4. Location and Device Signals

Where permitted by applicable law and with your permission where required, AzariPay may collect:

• GPS location;
• Approximate location derived from your IP address;
• Device location at the time of login or transaction;
• Country and region;
• Time zone information; and
• Device movement or behavioural signals used solely for fraud detection, account security, and regulatory compliance.

You may control location permissions through your device settings. Disabling certain permissions may affect the availability or functionality of some services.

5. Technical Logs

Our systems automatically generate technical logs that may include:

• System access logs;
• API request logs;
• Transaction processing logs;
• Server logs;
• Database logs;
• Security event logs;
• Network traffic logs;
• Error reports;
• Diagnostic reports; and
• Audit trails required for operational, security, legal, and regulatory purposes.

6. How We Use Device and Technical Information

We use this information to:

• Authenticate users and devices;
• Protect customer accounts against unauthorised access;
• Detect, prevent, and investigate fraud, cyber threats, and other unlawful activities;
• Monitor application performance and system stability;
• Troubleshoot technical issues;
• Improve our products, applications, and services;
• Maintain secure communications;
• Optimise website and mobile application functionality;
• Conduct security testing and vulnerability management;
• Comply with applicable legal and regulatory obligations;
• Maintain business continuity and disaster recovery capabilities; and
• Generate anonymised operational and performance analytics.

7. Sharing of Device and Technical Information

Where necessary, AzariPay may share relevant device and technical information with:

• Cloud hosting providers;
• Cybersecurity and fraud prevention service providers;
• Identity verification providers;
• Payment infrastructure partners;
• Technology vendors;
• Regulatory authorities;
• Law enforcement agencies where legally required;
• Auditors and professional advisers; and
• Other authorised service providers assisting in the delivery, protection, or improvement of our services.

Such disclosures are made only where necessary, lawful, and subject to appropriate confidentiality and security obligations.

8. Retention of Device and Technical Information

Device and technical information is retained only for as long as reasonably necessary to:

• Provide our services;
• Maintain security and fraud prevention measures;
• Investigate incidents;
• Resolve disputes;
• Comply with legal, regulatory, accounting, and audit obligations; and
• Protect the legitimate interests of AzariPay and its customers.

Retention periods may vary depending on the nature of the information and applicable legal requirements.

9. Automated Processing

Certain device and technical information may be processed using automated technologies to:

• Assess login risk;
• Detect suspicious activity;
• Identify unusual device behaviour;
• Prevent account compromise;
• Support fraud monitoring;
• Improve system performance; and
• Enhance customer security.

Automated processing may contribute to security-related decisions, but significant decisions affecting customers will be subject to appropriate safeguards and applicable legal requirements.

10. Customer Responsibilities

You are responsible for maintaining the security of the devices used to access AzariPay services. This includes keeping your operating system and applications up to date, using appropriate security features, protecting your login credentials, and promptly notifying AzariPay if you believe your device or account has been lost, stolen, compromised, or accessed without authorisation.

11. Aggregated and De-Identified Technical Data

AzariPay may aggregate or de-identify device and technical information so that it no longer identifies any individual. We may use such information for service improvement, capacity planning, cybersecurity research, product development, statistical reporting, operational analytics, and other legitimate business purposes, provided that the information cannot reasonably be linked to an identifiable person.

Cookies & Analytics

1. Use of Cookies and Similar Technologies

AzariPay Technologies Ltd (“AzariPay“, “we“, “our“, or “us“) uses cookies and similar technologies to provide, secure, improve, and personalise our products and services. These technologies help us understand how our website, mobile applications, and digital platforms are used, enhance performance, prevent fraud, and deliver a better customer experience.

By using our website or digital services, you acknowledge that AzariPay may use cookies and similar technologies as described in this Privacy Policy and our Cookie Policy, subject to your preferences and applicable law.

2. What Are Cookies?

Cookies are small text files placed on your computer, mobile phone, tablet, or other device when you visit a website or use certain online services. Cookies enable websites and applications to recognise your device, remember your preferences, maintain secure sessions, and improve functionality.

In addition to cookies, AzariPay may use:

• Software Development Kits (SDKs);
• Web beacons;
• Pixel tags;
• Local storage technologies;
• Device identifiers;
• Session tokens; and
• Other similar technologies that support the operation and security of our services.

3. Types of Cookies We Use
4. Strictly Necessary Cookies

These cookies are essential for the operation and security of our services. They enable core functionality such as:

• User authentication;
• Secure login sessions;
• Fraud prevention;
• Account security;
• Load balancing;
• Network management;
• Transaction processing; and
• System administration.

These cookies are generally required for the proper functioning of our services and cannot ordinarily be disabled.

1. Functional Cookies

Functional cookies help us remember your preferences and improve your experience by storing information such as:

• Language preferences;
• Region and country settings;
• Accessibility preferences;
• Display settings;
• User interface customisations; and
• Other account preferences.

1. Performance and Analytics Cookies

These cookies help us understand how users interact with our platforms by collecting information such as:

• Pages visited;
• Features used;
• Navigation patterns;
• Session duration;
• Error occurrences;
• Application performance;
• Website traffic statistics; and
• Customer engagement metrics.

This information helps us improve the reliability, usability, and performance of our services.

1. Security Cookies

Security cookies assist in protecting customers and our platforms by supporting:

• Detection of suspicious activity;
• Prevention of unauthorised access;
• Device recognition;
• Session integrity;
• Fraud detection;
• Risk analysis; and
• Cybersecurity monitoring.

1. Marketing and Personalisation Cookies

Where permitted by applicable law and with your consent where required, AzariPay may use cookies to:

• Measure the effectiveness of marketing campaigns;
• Understand customer interests;
• Deliver relevant content and promotions;
• Prevent repetitive advertising; and
• Improve customer communications.

AzariPay does not sell your personal information to third parties for targeted advertising.

4. Analytics Technologies

AzariPay may use internal analytics tools and carefully selected third-party analytics service providers to understand how our products and services are used.

Analytics information may include:

• Device information;
• Browser information;
• Operating system;
• Pages viewed;
• Click behaviour;
• Session duration;
• Navigation paths;
• Application performance;
• Error reports;
• Feature usage; and
• Aggregated customer behaviour.

Where possible, analytics information is aggregated or de-identified to minimise the identification of individual users.

5. Purpose of Cookies and Analytics

We use cookies and analytics technologies to:

• Operate and secure our website and applications;
• Authenticate users;
• Maintain secure sessions;
• Detect and prevent fraud;
• Improve customer experience;
• Remember customer preferences;
• Analyse platform performance;
• Improve products and services;
• Troubleshoot technical issues;
• Monitor system reliability;
• Conduct business intelligence and statistical analysis;
• Measure marketing effectiveness; and
• Comply with legal and regulatory obligations.

6. Third-Party Technologies

Some cookies or analytics technologies may be provided by trusted third-party service providers who support:

• Website hosting;
• Cloud infrastructure;
• Cybersecurity;
• Fraud prevention;
• Performance monitoring;
• Customer support;
• Analytics; and
• Marketing services.

These providers are contractually required to protect personal information, process it only for authorised purposes, and maintain appropriate security measures.

7. Managing Your Cookie Preferences

Most web browsers allow you to:

• View stored cookies;
• Delete cookies;
• Block certain cookies;
• Restrict third-party cookies;
• Configure browser privacy settings; and
• Receive notifications before cookies are stored.

You may also manage certain cookie preferences through settings made available on the AzariPay website where applicable.

Please note that disabling certain cookies may affect the availability, functionality, security, or performance of some features or services.

8. Do Not Track Signals

Some browsers transmit “Do Not Track” (DNT) signals. Because there is currently no universally accepted standard governing the interpretation of these signals, AzariPay does not guarantee that our systems will respond to all DNT requests. We will, however, continue to monitor legal and technological developments in this area.

9. Retention of Cookie Information

Cookie-related information is retained only for as long as necessary to fulfil the purposes described in this Privacy Policy, comply with legal obligations, resolve disputes, enforce our agreements, maintain security, and support the operation of our services.

Retention periods vary depending on the type of cookie or technology used.

10. Updates to Our Cookie Practices

AzariPay may update its use of cookies and analytics technologies from time to time as our products, services, technologies, or legal obligations evolve. Material changes will be communicated through appropriate channels, including updates to this Privacy Policy or our separate Cookie Policy where applicable.

Continued use of our services after such updates constitutes acknowledgement of the revised practices, except where applicable law requires renewed consent.

How We Use Personal Information

1. Our Purpose for Processing Personal Information

AzariPay Technologies Ltd (“AzariPay“, “we“, “our“, or “us“) processes personal information only where there is a lawful and legitimate purpose to do so. We use personal information to provide our financial products and services, comply with legal and regulatory obligations, protect our customers and business, improve our platforms, and deliver a secure and personalised customer experience.

The personal information we collect is used only for purposes that are compatible with this Privacy Policy and applicable law.

2. Providing Our Services

We use your personal information to:

• Open and manage your AzariPay account;
• Verify your identity and complete customer onboarding;
• Provide digital wallet, payment, foreign exchange, and cross-border payment services;
• Process deposits, withdrawals, transfers, and merchant payments;
• Issue and manage physical and virtual payment cards;
• Facilitate business banking and merchant solutions;
• Process recurring payments, payment requests, and bill payments;
• Deliver Azari Select concierge and lifestyle services;
• Provide customer support and respond to enquiries; and
• Deliver any other products or services requested by you.

3. Identity Verification and Regulatory Compliance

Your personal information may be used to:

• Conduct Know Your Customer (KYC) verification;
• Perform Customer Due Diligence (CDD) and Enhanced Due Diligence (EDD);
• Verify identity documents and biometric information where permitted by law;
• Comply with Anti-Money Laundering (AML), Counter-Terrorism Financing (CTF), sanctions, tax reporting, and other regulatory requirements;
• Screen customers against sanctions, Politically Exposed Person (PEP), and other watchlists;
• Report transactions or activities where required by law; and
• Maintain records required by regulators and applicable legislation.

4. Processing Transactions

We use personal information to:

• Authenticate payment instructions;
• Execute financial transactions;
• Process domestic and international transfers;
• Settle transactions with banks and payment partners;
• Verify recipients and beneficiaries;
• Process refunds, reversals, and chargebacks;
• Generate account statements and transaction histories; and
• Resolve payment disputes.

5. Fraud Prevention and Security

We use personal information to:

• Detect, prevent, investigate, and respond to fraud;
• Protect customer accounts from unauthorised access;
• Detect suspicious or unusual transaction patterns;
• Monitor device and account security;
• Prevent identity theft and financial crime;
• Protect the integrity of our systems;
• Investigate cybersecurity incidents; and
• Enforce our Terms and Conditions and other legal agreements.

6. Customer Communication

We may use your personal information to:

• Send account notifications;
• Deliver transaction confirmations;
• Provide security alerts;
• Notify you of important service updates;
• Respond to enquiries and complaints;
• Send customer satisfaction surveys;
• Provide technical support;
• Deliver legal or regulatory notices; and
• Contact you regarding your account or our services.

7. Improving Our Products and Services

We use information to:

• Analyse customer behaviour and usage patterns;
• Improve application performance and functionality;
• Develop new products and services;
• Enhance user experience;
• Test new features;
• Conduct quality assurance;
• Improve customer support; and
• Carry out research, innovation, and business planning.

Where practicable, such analysis will use aggregated or de-identified information.

8. Marketing and Personalisation

Where permitted by law and, where required, with your consent, we may use your personal information to:

• Inform you about new products and services;
• Offer promotions, rewards, and loyalty programmes;
• Deliver personalised recommendations;
• Invite you to events or campaigns;
• Measure the effectiveness of marketing initiatives; and
• Tailor communications to your preferences.

You may opt out of receiving marketing communications at any time using the unsubscribe options provided or by contacting AzariPay. Opting out of marketing messages will not affect service-related or legally required communications.

9. Business Operations

We use personal information to support our day-to-day operations, including:

• Financial reporting;
• Accounting and auditing;
• Risk management;
• Internal governance;
• Business continuity planning;
• Disaster recovery;
• Service administration;
• Contract management;
• Staff training and quality assurance; and
• Corporate planning.

10. Legal Rights and Enforcement

We may process personal information where necessary to:

• Protect the rights, property, or safety of AzariPay, our customers, employees, partners, or the public;
• Investigate suspected breaches of our agreements;
• Exercise or defend legal claims;
• Respond to court orders, subpoenas, or lawful requests;
• Cooperate with regulators, law enforcement agencies, or government authorities; and
• Enforce our contractual and legal rights.

11. Automated Decision-Making and Risk Assessment

AzariPay may use automated systems, including machine learning and artificial intelligence tools, to:

• Detect fraudulent or suspicious activities;
• Assess transaction risk;
• Identify account security threats;
• Monitor compliance with applicable laws;
• Improve fraud prevention capabilities; and
• Support operational decision-making.

Where automated processing results in decisions that produce legal or similarly significant effects on individuals, AzariPay will implement appropriate safeguards and comply with applicable legal requirements.

12. Use of Aggregated and De-Identified Information

AzariPay may aggregate, anonymise, or otherwise de-identify personal information so that it no longer identifies any individual. Such information may be used for:

• Statistical analysis;
• Product development;
• Operational reporting;
• Service improvement;
• Market research;
• Performance measurement;
• Artificial intelligence model training using non-identifiable data;
• Regulatory reporting; and
• Other legitimate business purposes.

Aggregated or de-identified information is not considered personal information where it cannot reasonably be linked to an identifiable individual.

13. Additional Compatible Purposes

AzariPay may process personal information for any other purpose that is:

• Consistent with this Privacy Policy;
• Necessary to provide our services;
• Required or authorised by applicable law;
• Based on your consent; or
• Reasonably related to the purpose for which the information was originally collected.

Where required by law, we will notify you of any material change in the purpose for processing your personal information and obtain your consent before processing it for a new purpose that is incompatible with the original purpose of collection.

Legal Bases for Processing

1. Our Legal Basis for Processing Personal Information

AzariPay Technologies Ltd (“AzariPay“, “we“, “our“, or “us“) processes personal information only where we have a lawful basis to do so under applicable data protection, financial services, anti-money laundering, cybersecurity, consumer protection, and other applicable laws and regulations.

Depending on the nature of our relationship with you and the services you use, one or more of the following legal bases may apply.

2. Performance of a Contract

We process personal information where it is necessary to enter into, perform, administer, or enforce a contract with you or your organisation.

This includes processing necessary to:

• Open and manage your AzariPay account;
• Verify your identity during onboarding;
• Process payments and financial transactions;
• Provide digital wallet, card, merchant, business banking, foreign exchange, and cross-border payment services;
• Deliver Azari Select concierge and lifestyle services;
• Provide customer support;
• Process refunds, reversals, and disputes;
• Manage subscriptions and service requests; and
• Perform any obligations arising under our Terms and Conditions or other agreements.

Without this processing, we may be unable to provide some or all of our services.

3. Compliance with Legal and Regulatory Obligations

We process personal information where necessary to comply with applicable laws, regulations, regulatory directives, court orders, and lawful requests from competent authorities.

This includes compliance with obligations relating to:

• Know Your Customer (KYC);
• Anti-Money Laundering (AML);
• Counter-Terrorism Financing (CTF);
• Counter-Proliferation Financing (CPF);
• Financial crime prevention;
• Sanctions screening;
• Tax reporting;
• Consumer protection;
• Cybersecurity;
• Financial record-keeping;
• Audit requirements;
• Regulatory reporting;
• Data protection laws; and
• Any other applicable legal or regulatory requirement.

Where required by law, AzariPay may disclose personal information to regulators, courts, law enforcement agencies, tax authorities, financial intelligence units, or other authorised public authorities.

4. Legitimate Business Interests

We may process personal information where such processing is reasonably necessary for our legitimate business interests, provided that those interests are not overridden by your fundamental rights and freedoms.

Our legitimate interests include:

• Preventing fraud and financial crime;
• Protecting customers and our platforms;
• Maintaining network and information security;
• Improving our products and services;
• Conducting internal analytics and business intelligence;
• Monitoring service performance;
• Managing operational risks;
• Training employees and improving customer support;
• Defending legal claims;
• Enforcing our contractual rights;
• Conducting internal investigations;
• Business continuity planning;
• Corporate governance;
• Auditing and quality assurance; and
• Developing new products and technologies.

Before relying on legitimate interests, AzariPay considers the impact of the processing on your rights and implements appropriate safeguards where necessary.

5. Your Consent

Where required by applicable law, AzariPay will obtain your consent before processing your personal information.

Consent may be requested for activities such as:

• Marketing communications;
• Optional cookies and analytics technologies;
• Certain location-based services;
• Optional biometric authentication features;
• Promotional campaigns;
• Surveys;
• Participation in research initiatives; and
• Other processing activities where consent is legally required.

You may withdraw your consent at any time. Withdrawal of consent will not affect the lawfulness of processing carried out before the withdrawal, nor will it affect processing carried out on another lawful basis.

6. Protection of Vital Interests

Where necessary, AzariPay may process personal information to protect the vital interests of an individual or another person.

Examples include:

• Preventing imminent financial harm;
• Responding to security incidents;
• Protecting customers from fraud or identity theft;
• Assisting emergency responders where legally appropriate; and
• Protecting individuals from serious threats affecting life, health, or safety.

7. Public Interest and Exercise of Official Authority

Where permitted or required by applicable law, AzariPay may process personal information for reasons of substantial public interest or in support of functions carried out by public authorities, including:

• Crime prevention and investigation;
• Financial system integrity;
• Regulatory oversight;
• National security;
• Compliance with lawful governmental directives; and
• Other purposes recognised by applicable law.

8. Automated Processing

Certain personal information may be processed using automated systems, including artificial intelligence, machine learning, fraud detection tools, behavioural analytics, and risk assessment technologies.

Such processing is used to:

• Detect fraud;
• Prevent unauthorised access;
• Monitor suspicious transactions;
• Strengthen cybersecurity;
• Improve operational efficiency; and
• Support regulatory compliance.

Where automated processing results in decisions that have legal or similarly significant effects on individuals, AzariPay will implement appropriate safeguards, including opportunities for review where required by applicable law.

9. Multiple Legal Bases

More than one legal basis may apply to the same processing activity. For example, processing a payment transaction may be necessary both to perform our contract with you and to comply with legal obligations relating to anti-money laundering and financial record-keeping.

10. Changes to the Legal Basis

If the legal basis on which we process your personal information changes, AzariPay will ensure that the new basis is permitted under applicable law. Where required, we will notify you and obtain your consent before processing your personal information for a materially different purpose that is incompatible with the original purpose for which it was collected.

11. Data Minimisation and Purpose Limitation

Regardless of the legal basis relied upon, AzariPay is committed to:

• Collecting only personal information that is relevant and reasonably necessary for the identified purpose;
• Processing personal information fairly, lawfully, and transparently;
• Limiting processing to the purposes described in this Privacy Policy or otherwise permitted by law;
• Maintaining the accuracy of personal information;
• Protecting personal information with appropriate technical and organisational safeguards; and
• Retaining personal information only for as long as necessary to fulfil the relevant purpose or comply with applicable legal obligations.

Fraud Prevention & Anti-Money Laundering (AML) Compliance

1. Our Commitment

AzariPay Technologies Ltd (“AzariPay“, “we“, “our“, or “us“) is committed to maintaining a secure, trusted, and compliant financial ecosystem. We implement robust measures to prevent, detect, investigate, and report fraud, money laundering, terrorist financing, proliferation financing, sanctions violations, cybercrime, identity theft, and other unlawful or suspicious activities.

Our fraud prevention and financial crime compliance programme is designed to protect our customers, business partners, shareholders, employees, and the integrity of the financial system while complying with applicable laws and regulatory requirements.

2. Monitoring and Detection

To protect our platform and customers, AzariPay may continuously monitor accounts, transactions, devices, and customer activities using manual reviews and automated technologies.

Monitoring activities may include:

• Transaction monitoring;
• Behavioural analysis;
• Device and account risk assessments;
• Login and authentication monitoring;
• Fraud detection algorithms;
• Artificial intelligence and machine learning models;
• Velocity and transaction pattern analysis;
• Geolocation and device consistency checks;
• Merchant risk monitoring;
• Chargeback and dispute analysis;
• Account takeover detection;
• Identity verification monitoring; and
• Other lawful security and compliance measures.

Monitoring may occur before, during, or after transactions are processed.

3. Anti-Money Laundering (AML) and Counter-Terrorism Financing (CTF)

AzariPay maintains a comprehensive AML/CTF compliance programme that may include:

• Know Your Customer (KYC) procedures;
• Customer Due Diligence (CDD);
• Enhanced Due Diligence (EDD) for higher-risk customers;
• Ongoing customer risk assessments;
• Beneficial ownership verification;
• Source of funds and source of wealth verification where appropriate;
• Transaction monitoring;
• Sanctions screening;
• Politically Exposed Person (PEP) screening;
• Adverse media screening;
• Suspicious activity detection;
• Record keeping; and
• Reporting to competent authorities where required by law.

4. Screening Against Watchlists

To comply with legal and regulatory obligations, AzariPay may screen customers, authorised representatives, beneficial owners, counterparties, merchants, and transactions against:

• National and international sanctions lists;
• Politically Exposed Person (PEP) databases;
• Financial crime watchlists;
• Fraud prevention databases;
• Regulatory enforcement lists;
• Law enforcement alerts;
• Adverse media databases; and
• Other legally recognised screening sources.

Screening may be performed during onboarding, periodically throughout the customer relationship, and whenever transactions are initiated or processed.

5. Information Sharing for Fraud Prevention

Where necessary and permitted or required by applicable law, AzariPay may share relevant information with:

• Financial institutions;
• Payment processors;
• Card schemes;
• Identity verification providers;
• Fraud prevention organisations;
• Credit reference agencies where applicable;
• Regulatory authorities;
• Financial Intelligence Units (FIUs);
• Tax authorities;
• Law enforcement agencies;
• Courts and tribunals;
• Auditors and professional advisers; and
• Other authorised entities involved in fraud prevention, financial crime investigations, or regulatory compliance.

Such disclosures will be limited to what is reasonably necessary and will be subject to appropriate legal, contractual, and security safeguards.

6. Risk-Based Decisions

To protect customers and comply with legal obligations, AzariPay may, based on its risk assessment:

• Request additional identity verification or supporting documentation;
• Delay or decline the processing of a transaction;
• Place temporary restrictions on an account;
• Suspend or limit access to specific services;
• Freeze funds where required or authorised by applicable law;
• Refuse to establish or continue a business relationship; or
• Close an account in accordance with our Terms and Conditions and applicable law.

Where appropriate and legally permissible, we may provide information about such actions. However, AzariPay reserves the right to withhold information where disclosure could prejudice an investigation, facilitate unlawful activity, compromise security measures, or breach legal or regulatory obligations.

7. Customer Responsibilities

Customers are responsible for:

• Providing accurate and complete information during onboarding and throughout the customer relationship;
• Protecting login credentials, devices, and authentication methods;
• Promptly reporting suspected unauthorised access or fraudulent activity;
• Cooperating with fraud investigations and compliance reviews;
• Responding to requests for updated KYC information; and
• Using AzariPay services only for lawful purposes.

Failure to cooperate with fraud prevention or compliance measures may result in restrictions on the account or termination of the customer relationship where permitted by law.

8. Record Retention

AzariPay retains fraud prevention, compliance, investigation, and AML-related records for the periods required by applicable law or as reasonably necessary to:

• Meet legal and regulatory obligations;
• Support investigations;
• Resolve disputes;
• Defend legal claims;
• Conduct audits; and
• Protect the legitimate interests of AzariPay and its customers.

9. No Liability for Lawful Compliance Actions

To the fullest extent permitted by applicable law, AzariPay shall not be liable for any loss, delay, restriction, suspension, declined transaction, account freeze, reporting, disclosure, or other action taken in good faith to comply with applicable laws, regulatory requirements, court orders, sanctions obligations, fraud prevention measures, or financial crime compliance obligations.

Nothing in this Privacy Policy limits AzariPay’s obligation to comply with applicable laws or the lawful directions of competent authorities.

10. Customer Acknowledgement

By applying for, accessing, or using any AzariPay product or service, you acknowledge and agree that AzariPay may collect, analyse, monitor, verify, and process your personal information and transaction information for fraud prevention, security, AML, CTF, sanctions compliance, risk management, regulatory reporting, and other lawful compliance purposes.

You further acknowledge that AzariPay may use automated technologies, including artificial intelligence and machine learning, to support fraud detection and financial crime prevention, subject to appropriate legal safeguards and applicable data protection laws.

Information Sharing

1. Our Approach to Sharing Information

AzariPay Technologies Ltd (“AzariPay“, “we“, “our“, or “us“) treats your personal information as confidential and shares it only where necessary to provide our services, comply with legal and regulatory obligations, protect our legitimate interests, prevent fraud and financial crime, or where you have authorised us to do so.

We do not sell, rent, or trade your personal information to third parties for their independent marketing purposes.

2. Categories of Information We May Share

Depending on the services you use, AzariPay may share:

• Identity and KYC information;
• Contact information;
• Account information;
• Transaction information;
• Payment instructions;
• Merchant information;
• Device and technical information;
• Fraud prevention and risk assessment information;
• Customer support records;
• Compliance records; and
• Other information reasonably necessary for the purposes described in this Privacy Policy.

3. Sharing with Financial Institutions and Payment Partners

To process transactions and provide financial services, we may share relevant information with:

• Banks and other licensed financial institutions;
• Payment processors and payment gateways;
• Card schemes and payment networks;
• Correspondent banking partners;
• Foreign exchange providers;
• Settlement institutions;
• Digital payment service providers;
• Mobile money operators;
• Payment infrastructure providers; and
• Other financial service providers involved in processing your transactions.

Only information necessary to complete or support the relevant transaction will be shared.

4. Sharing with Identity Verification and Fraud Prevention Providers

To verify identities and protect our platform, AzariPay may share information with trusted service providers that perform:

• Identity verification;
• Electronic KYC (e-KYC);
• Biometric verification where permitted by law;
• Fraud detection and prevention;
• Device risk analysis;
• Cybersecurity monitoring;
• Transaction monitoring;
• Sanctions screening;
• Politically Exposed Person (PEP) screening;
• Adverse media screening; and
• Other compliance-related services.

5. Sharing with Regulators and Government Authorities

Where required or authorised by applicable law, AzariPay may disclose personal information to:

• Financial regulators;
• Data protection authorities;
• Tax authorities;
• Financial Intelligence Units (FIUs);
• Central banks;
• Law enforcement agencies;
• Anti-corruption agencies;
• Courts and tribunals;
• Government ministries, departments, and agencies; and
• Other competent public authorities.

Such disclosures may be made without prior notice where notification is prohibited by law or could prejudice an investigation or regulatory action.

6. Sharing with Service Providers

AzariPay may engage carefully selected third-party service providers to support our operations, including providers of:

• Cloud hosting and infrastructure;
• Data storage;
• Cybersecurity services;
• Customer support;
• Communications services;
• Analytics;
• Technology development;
• Payment processing;
• Identity verification;
• Professional advisory services;
• Audit services;
• Business continuity and disaster recovery;
• Document management; and
• Other operational support services.

These providers are contractually required to:

• Process personal information only on AzariPay’s instructions;
• Maintain appropriate confidentiality;
• Implement suitable technical and organisational security measures;
• Comply with applicable data protection laws; and
• Return or securely delete personal information when no longer required, where appropriate.

7. Sharing with Business Partners

Where necessary to provide products or services requested by you, AzariPay may share relevant information with:

• Merchants;
• Corporate customers;
• Business partners;
• Loyalty programme partners;
• Azari Select concierge partners;
• Rewards and promotional partners;
• Insurance providers where applicable;
• Travel and lifestyle service providers connected with Azari Select; and
• Other partners involved in delivering requested services.

Only information reasonably necessary to deliver the requested service will be disclosed.

8. Corporate Transactions

If AzariPay undergoes a merger, acquisition, restructuring, financing, joint venture, sale of assets, investment transaction, or other corporate reorganisation, personal information may be disclosed to prospective or actual investors, purchasers, lenders, advisers, or successor entities, subject to appropriate confidentiality obligations and applicable law.

9. Legal Protection

AzariPay may disclose personal information where we reasonably believe such disclosure is necessary to:

• Protect our legal rights;
• Enforce our Terms and Conditions or other agreements;
• Prevent fraud or financial crime;
• Protect the safety of customers, employees, or the public;
• Respond to legal claims;
• Defend ourselves in legal proceedings;
• Investigate suspected unlawful conduct; or
• Protect the integrity and security of our systems and services.

10. International Information Sharing

Where our services involve international payments, cross-border operations, cloud infrastructure, global account services, or international business partners, your personal information may be transferred to or accessed from countries outside your country of residence.

AzariPay will implement appropriate contractual, technical, organisational, and legal safeguards to protect such information in accordance with applicable data protection laws.

11. Information Shared with Your Consent

Where required by law or where processing is not otherwise authorised, AzariPay will obtain your consent before sharing your personal information with third parties.

You may withdraw your consent at any time where processing is based solely on consent. Withdrawal will not affect the lawfulness of any processing carried out before consent was withdrawn.

12. Aggregated and De-Identified Information

AzariPay may share aggregated, anonymised, or de-identified information that cannot reasonably identify any individual with:

• Business partners;
• Researchers;
• Industry bodies;
• Regulators;
• Investors;
• Service providers; and
• Other organisations,

for purposes such as research, analytics, product development, market intelligence, operational reporting, and industry benchmarking.

13. Data Security During Information Sharing

Whenever AzariPay shares personal information, we implement reasonable technical and organisational safeguards designed to protect the confidentiality, integrity, and security of the information. These safeguards may include encryption, secure communication channels, contractual confidentiality obligations, access controls, authentication measures, audit logging, and ongoing monitoring of third-party compliance.

14. Limitation of Responsibility

While AzariPay exercises reasonable care in selecting and monitoring third-party service providers and partners, we cannot guarantee the privacy or security practices of independent third parties that are not under our control. Once information is lawfully disclosed to a third party in accordance with this Privacy Policy or applicable law, that third party is responsible for handling the information in accordance with its own legal obligations and privacy practices.

International Data Transfers

1. Cross-Border Nature of Our Services

AzariPay Technologies Ltd (“AzariPay“, “we“, “our“, or “us“) provides digital financial services that may involve international payments, global accounts, foreign exchange, cloud infrastructure, international business operations, and partnerships with financial institutions and service providers located in different countries.

As a result, your personal information may be transferred to, stored in, accessed from, or processed in jurisdictions outside your country of residence.

2. Circumstances in Which We Transfer Personal Information

We may transfer personal information internationally where necessary to:

• Process international and cross-border payment transactions;
• Provide global account and foreign exchange services;
• Verify customer identities through international verification providers;
• Perform fraud prevention, cybersecurity, and financial crime monitoring;
• Screen customers against international sanctions and compliance databases;
• Use cloud hosting, disaster recovery, or secure data storage services;
• Provide customer support through authorised international service centres;
• Support our subsidiaries, affiliates, and representative offices;
• Engage trusted technology vendors, payment processors, and professional advisers; or
• Comply with legal, regulatory, contractual, or operational requirements.

3. Countries to Which Information May Be Transferred

Personal information may be transferred to countries in which AzariPay, its affiliates, business partners, financial institutions, payment networks, cloud providers, or authorised service providers operate.

These countries may have privacy or data protection laws that differ from those applicable in your country of residence.

4. Our Safeguards

Before transferring personal information internationally, AzariPay will implement appropriate safeguards designed to protect your information, which may include:

• Transfers to jurisdictions recognised as providing an adequate level of data protection under applicable law;
• Legally binding data transfer agreements;
• Standard contractual clauses or equivalent contractual safeguards where recognised by applicable law;
• Data processing agreements with service providers;
• Confidentiality obligations;
• Encryption of personal information during transmission and, where appropriate, at rest;
• Access controls and authentication measures;
• Security monitoring and auditing; and
• Other technical, organisational, and contractual measures appropriate to the nature of the transfer.

5. Compliance with Applicable Data Protection Laws

AzariPay will conduct international data transfers in accordance with applicable data protection laws, including the Nigeria Data Protection Act, 2023 (NDPA) and any other applicable privacy legislation governing the transfer of personal information.

Where required by law, we will ensure that a lawful transfer mechanism is in place before transferring your personal information outside the applicable jurisdiction.

6. Sharing with International Financial Institutions

Where you initiate or receive international payments, AzariPay may disclose relevant personal and transaction information to:

• Foreign banks;
• Correspondent banks;
• Payment schemes;
• Card networks;
• Settlement institutions;
• Foreign exchange providers;
• International payment processors;
• Financial messaging networks;
• Regulatory authorities; and
• Other financial institutions involved in processing the transaction.

Such disclosures are limited to the information reasonably necessary to complete the transaction, comply with legal obligations, or protect the integrity of the financial system.

7. Regulatory and Legal Disclosures

International transfers may also occur where required to:

• Comply with court orders or lawful governmental requests;
• Meet international sanctions obligations;
• Support anti-money laundering and counter-terrorism financing requirements;
• Respond to lawful requests from regulators or supervisory authorities;
• Protect AzariPay’s legal rights;
• Investigate fraud or financial crime; or
• Defend or pursue legal claims.

8. Customer Acknowledgement

By opening an account, using AzariPay’s services, or initiating a transaction that involves an international element, you acknowledge and understand that your personal information may be transferred across international borders in accordance with this Privacy Policy and applicable law.

Where your consent is required by applicable law for a specific transfer, AzariPay will obtain such consent before proceeding.

9. Security of International Transfers

Regardless of where your personal information is processed, AzariPay applies reasonable technical, organisational, and administrative safeguards to protect it against unauthorised access, disclosure, alteration, loss, or misuse.

These safeguards may include encryption, secure communications, identity and access management, monitoring, incident response procedures, contractual confidentiality obligations, and regular security reviews.

10. Limitation of Liability

While AzariPay exercises reasonable care in selecting reputable international service providers and implementing appropriate safeguards, no method of electronic transmission or international data transfer can be guaranteed to be completely secure.

To the fullest extent permitted by applicable law, AzariPay shall not be liable for losses arising solely from acts or omissions of independent third parties, foreign regulators, telecommunications providers, payment infrastructures, or events beyond our reasonable control, provided that AzariPay has implemented appropriate safeguards and complied with its legal obligations.

11. Future International Expansion

As AzariPay expands its operations into additional countries and territories, this Privacy Policy shall apply to all international transfers of personal information undertaken in connection with our products and services. AzariPay may update its transfer mechanisms and safeguards from time to time to reflect changes in applicable law, regulatory guidance, technological developments, or business operations.

Data Security

1. Our Commitment to Data Security

AzariPay Technologies Ltd (“AzariPay“, “we“, “our“, or “us“) is committed to protecting the confidentiality, integrity, availability, and resilience of the personal information entrusted to us. We implement appropriate technical, organisational, administrative, and physical security measures designed to safeguard personal information against accidental or unlawful destruction, loss, alteration, unauthorised disclosure, unauthorised access, misuse, theft, or other forms of unlawful processing.

Our information security programme is regularly reviewed and updated to address evolving cyber threats, technological developments, regulatory requirements, and industry best practices.

2. Security Measures We Implement

Depending on the nature of the information and associated risks, AzariPay may implement security measures including:

• End-to-end encryption of data during transmission where appropriate;
• Encryption of sensitive data at rest;
• Secure Socket Layer (SSL) and Transport Layer Security (TLS) technologies;
• Firewalls and network security controls;
• Multi-factor authentication (MFA);
• Strong password and authentication policies;
• Identity and access management controls;
• Role-based access restrictions;
• Secure application development practices;
• Security monitoring and logging;
• Intrusion detection and prevention systems;
• Anti-malware and endpoint protection;
• Security information and event management (SIEM) solutions;
• Vulnerability assessments and penetration testing;
• Regular software updates and security patch management;
• Secure backup and disaster recovery systems; and
• Physical security measures protecting facilities and infrastructure.

3. Access Controls

Access to personal information is limited to employees, contractors, service providers, and authorised representatives who have a legitimate business need to access such information in the performance of their duties.

Individuals with access to personal information are required to:

• Comply with confidentiality obligations;
• Follow AzariPay’s information security policies;
• Complete appropriate security and privacy training; and
• Access personal information only to the extent necessary for authorised business purposes.

Unauthorised access to customer information is strictly prohibited and may result in disciplinary action, termination of engagement, civil liability, or criminal prosecution where applicable.

4. Employee Confidentiality

All employees, consultants, contractors, and authorised personnel with access to personal information are subject to appropriate confidentiality obligations, information security policies, and contractual restrictions designed to protect customer information.

Access permissions are regularly reviewed and revoked when no longer required.

5. Security Monitoring

AzariPay continuously monitors its systems, applications, and infrastructure to identify, detect, investigate, and respond to security threats.

Monitoring activities may include:

• Security event monitoring;
• Network traffic analysis;
• Fraud detection;
• Account activity monitoring;
• Threat intelligence;
• Vulnerability scanning;
• Audit logging;
• System health monitoring;
• Incident detection; and
• Security investigations.

6. Incident Response

AzariPay maintains an information security incident response programme designed to:

• Detect and assess security incidents;
• Contain and minimise potential harm;
• Investigate the root cause;
• Restore affected systems;
• Preserve relevant evidence where appropriate;
• Implement corrective actions;
• Notify competent regulatory authorities where required by law; and
• Notify affected individuals where legally required and appropriate.

7. Customer Responsibilities

While AzariPay employs robust security measures, customers also play an important role in protecting their accounts.

You are responsible for:

• Keeping your password, PIN, OTPs, passcodes, and authentication credentials confidential;
• Enabling available security features such as multi-factor authentication where offered;
• Protecting the devices used to access AzariPay services;
• Keeping your operating system and applications updated;
• Avoiding the disclosure of sensitive account information to unauthorised persons;
• Verifying communications claiming to originate from AzariPay;
• Promptly reporting suspected fraud, phishing, unauthorised access, or security incidents; and
• Logging out of shared or public devices after use.

AzariPay will never ask you to disclose your password, PIN, OTP, or full authentication credentials through unsolicited calls, emails, text messages, or social media.

8. Third-Party Security

Where AzariPay engages third-party service providers that process personal information on our behalf, we take reasonable steps to ensure they implement appropriate security measures consistent with applicable laws, contractual obligations, and industry standards.

However, independent third-party organisations remain responsible for the security of their own systems and operations.

9. Data Retention and Secure Disposal

Personal information is retained only for as long as necessary to fulfil the purposes for which it was collected, comply with legal and regulatory obligations, resolve disputes, enforce our agreements, and protect our legitimate interests.

When personal information is no longer required, it will be securely deleted, destroyed, anonymised, or otherwise disposed of using appropriate methods designed to prevent unauthorised recovery or reconstruction.

10. No Absolute Security Guarantee

Although AzariPay employs commercially reasonable and industry-recognised security measures, no method of transmitting information over the internet, electronic storage system, mobile network, or information technology infrastructure can be guaranteed to be completely secure or immune from cyber threats.

Accordingly, while we strive to protect your personal information, AzariPay cannot guarantee absolute security and does not warrant that its systems will be free from interruption, unauthorised access, cyberattacks, malware, or other security incidents beyond our reasonable control.

11. Limitation of Liability

To the fullest extent permitted by applicable law, AzariPay shall not be liable for any loss, damage, unauthorised access, disclosure, alteration, or destruction of personal information arising from:

• Acts or omissions of the customer;
• Compromise of customer devices or credentials;
• Failure by the customer to follow reasonable security practices;
• Cyberattacks or malicious activities beyond AzariPay’s reasonable control;
• Failures of telecommunications providers, internet service providers, cloud infrastructure, payment networks, or other independent third parties;
• Force majeure events; or
• Any other event where AzariPay has implemented reasonable and appropriate security measures consistent with applicable law and industry standards.

Nothing in this Privacy Policy excludes or limits any liability that cannot lawfully be excluded under applicable law.

12. Continuous Improvement

AzariPay continually evaluates, tests, and enhances its information security framework to address emerging threats, technological developments, business changes, and evolving regulatory requirements. We may update our security controls, policies, and procedures at any time to maintain the confidentiality, integrity, availability, and resilience of our services and the personal information entrusted to us.

Data Retention

1. Our Data Retention Principles

AzariPay Technologies Ltd (“AzariPay“, “we“, “our“, or “us“) retains personal information only for as long as is necessary to fulfil the purposes for which it was collected, including providing our services, complying with legal and regulatory obligations, protecting our legitimate business interests, resolving disputes, preventing fraud, enforcing our agreements, and maintaining appropriate business records.

Our retention practices are guided by applicable data protection laws, financial services regulations, anti-money laundering requirements, taxation laws, accounting standards, and other legal obligations.

2. How Long We Retain Personal Information

The length of time we retain personal information depends on the nature of the information, the services provided, applicable legal requirements, and operational needs.

We may retain personal information for purposes including:

• Maintaining customer accounts;
• Processing and verifying transactions;
• Meeting Know Your Customer (KYC) obligations;
• Complying with Anti-Money Laundering (AML) and Counter-Terrorism Financing (CTF) regulations;
• Responding to regulatory enquiries;
• Supporting audits and financial reporting;
• Investigating fraud and security incidents;
• Resolving complaints and disputes;
• Defending or pursuing legal claims; and
• Maintaining business continuity and operational records.

3. Typical Categories of Retention

Subject to applicable law, AzariPay may retain the following categories of information for different periods:

• Customer Identification Records – retained for the period required by applicable KYC, AML, CTF, sanctions, and financial services regulations.
• Transaction Records – retained for the period required by financial, accounting, taxation, audit, and regulatory obligations.
• Communication Records – retained for customer support, dispute resolution, quality assurance, regulatory compliance, and legal purposes.
• Device and Security Logs – retained for cybersecurity, fraud prevention, system monitoring, and incident investigation.
• Marketing Preferences – retained until you withdraw your consent or unsubscribe, unless longer retention is required by law.
• Recruitment Records – retained only for as long as necessary to complete recruitment activities or comply with legal obligations.
• Investigation Records – retained for as long as necessary to complete investigations, comply with legal requirements, or defend legal claims.

Actual retention periods may vary depending on the applicable laws and the specific circumstances of each record.

4. Closed or Inactive Accounts

If your AzariPay account is closed, suspended, or becomes inactive, we may continue to retain relevant personal information where necessary to:

• Comply with applicable legal or regulatory requirements;
• Prevent fraud and financial crime;
• Resolve disputes;
• Complete outstanding transactions;
• Respond to lawful requests from regulators or law enforcement authorities;
• Protect the rights and legitimate interests of AzariPay or third parties; and
• Enforce our Terms and Conditions and other legal agreements.

Closure of your account does not automatically require the deletion of all personal information.

5. Legal Holds

Notwithstanding any other provision of this Privacy Policy, AzariPay may retain personal information for longer than its standard retention period where reasonably necessary to:

• Comply with a court order;
• Respond to regulatory investigations;
• Satisfy legal or statutory obligations;
• Preserve evidence;
• Investigate fraud, cybercrime, or other unlawful activities;
• Protect our legal rights; or
• Defend or pursue legal proceedings.

Such information will be retained only for as long as necessary for the relevant purpose.

6. Secure Deletion and Disposal

When personal information is no longer required, AzariPay will take reasonable steps to securely:

• Delete electronic records;
• Destroy physical documents;
• Permanently erase storage media where appropriate;
• Anonymise or de-identify information; or
• Dispose of records using secure methods designed to prevent unauthorised access, reconstruction, or recovery.

The method of disposal will depend on the nature, sensitivity, and format of the information.

7. Anonymised Information

AzariPay may retain anonymised, aggregated, or de-identified information indefinitely where such information can no longer reasonably identify an individual.

Such information may be used for:

• Statistical analysis;
• Product development;
• Service improvement;
• Business intelligence;
• Operational planning;
• Research;
• Regulatory reporting; and
• Other lawful business purposes.

Information that has been irreversibly anonymised is not treated as personal information under this Privacy Policy.

8. Backup and Disaster Recovery Copies

Personal information may continue to exist in secure backup systems for a limited period after deletion from active systems where necessary to support:

• Disaster recovery;
• Business continuity;
• System resilience;
• Regulatory compliance; and
• Information security.

Backup data remains subject to appropriate technical and organisational security measures and will be securely overwritten or deleted in accordance with AzariPay’s backup management procedures.

9. Customer Requests for Deletion

Where permitted by applicable law, you may request the deletion of your personal information.

AzariPay may decline or partially fulfil such requests where retention is necessary to:

• Comply with legal obligations;
• Complete pending transactions;
• Detect or prevent fraud;
• Protect public interests;
• Exercise or defend legal claims;
• Enforce contractual obligations; or
• Maintain records required by financial services regulations.

Where deletion cannot be completed, we will inform you of the legal basis for continued retention, unless prohibited by law.

10. Periodic Review

AzariPay periodically reviews the personal information it holds to ensure that:

• Information is not retained longer than necessary;
• Retention schedules remain consistent with applicable laws and regulations;
• Security controls remain appropriate throughout the retention period; and
• Personal information that is no longer required is securely deleted, destroyed, anonymised, or archived in accordance with this Privacy Policy and our internal records management policies.

11. Changes to Retention Practices

AzariPay may update its retention schedules and records management practices from time to time to reflect changes in applicable laws, regulatory requirements, technological developments, operational needs, or industry best practices.

Material changes will be communicated through updates to this Privacy Policy or by other appropriate means where required by law.

Marketing Preferences

1. Marketing Communications

AzariPay Technologies Ltd (“AzariPay“, “we“, “our“, or “us“) may use your personal information to communicate with you about our products, services, promotions, offers, events, rewards, loyalty programmes, and other information that may be of interest to you.

Marketing communications are intended to keep you informed about opportunities that enhance your experience with AzariPay while respecting your privacy and communication preferences.

2. Types of Marketing Communications

Subject to applicable law and your communication preferences, we may send you information relating to:

• New AzariPay products and services;
• Digital wallet features and enhancements;
• Azari Select benefits, concierge services, and exclusive offers;
• Merchant discounts and partner promotions;
• Foreign exchange and cross-border payment services;
• Rewards, loyalty programmes, and referral campaigns;
• Competitions, giveaways, surveys, and promotional events;
• Financial education and product updates;
• Security awareness campaigns; and
• Other information that we reasonably believe may be relevant to you.

3. Communication Channels

Marketing communications may be delivered through one or more of the following channels:

• Email;
• SMS;
• Push notifications;
• In-app messages;
• Telephone calls, where permitted by law;
• WhatsApp or other messaging platforms where supported;
• Social media platforms;
• Website banners and personalised content; and
• Other electronic communication channels approved by you or permitted under applicable law.

4. Your Marketing Choices

Where required by applicable law, AzariPay will obtain your consent before sending direct marketing communications.

You may choose to:

• Subscribe to marketing communications;
• Decline marketing communications during registration;
• Update your communication preferences at any time;
• Unsubscribe from specific categories of marketing messages; or
• Withdraw your consent where marketing is based solely on your consent.

You may exercise these choices through your account settings, the unsubscribe link in our communications, or by contacting our Customer Support team.

5. Service Communications

Even if you choose not to receive marketing communications, AzariPay may still send you important non-marketing communications that are necessary to provide our services or comply with legal obligations.

These communications may include:

• Transaction confirmations;
• Security alerts;
• One-Time Passwords (OTPs);
• Account verification messages;
• Changes to our Terms and Conditions or Privacy Policy;
• Regulatory notices;
• Service interruption notices;
• Fraud prevention alerts;
• Password reset notifications; and
• Other essential account-related communications.

These communications are not promotional in nature and cannot generally be opted out of while you maintain an active relationship with AzariPay.

6. Personalisation

Subject to applicable law, AzariPay may use information about your interactions with our products and services to personalise marketing communications and recommend products or services that are more relevant to your interests and preferences.

Personalisation may be based on:

• Products you use;
• Transaction history;
• Account preferences;
• Device and application usage;
• Geographic region;
• Language preferences;
• Customer segment; and
• Other information collected in accordance with this Privacy Policy.

We do not use sensitive personal information for marketing purposes without an appropriate legal basis.

7. Third-Party Marketing

AzariPay does not sell, rent, or disclose your personal information to third parties for their independent marketing purposes.

Where we collaborate with merchants, business partners, or Azari Select partners on joint promotions, your personal information will only be shared where:

• You have expressly consented;
• It is necessary to deliver a benefit or service you requested;
• The sharing is otherwise permitted by applicable law; and
• Appropriate contractual safeguards are in place.

8. Marketing Analytics

We may analyse the effectiveness of our marketing campaigns using aggregated or de-identified information, including:

• Email open rates;
• Click-through rates;
• Website visits;
• Application engagement;
• Campaign participation;
• Customer response rates; and
• Overall campaign performance.

Where practicable, such analytics are conducted using anonymised or aggregated information.

9. Withdrawal of Consent

Where marketing communications are based on your consent, you may withdraw that consent at any time.

Withdrawal of consent:

• Will not affect the lawfulness of processing carried out before the withdrawal;
• Will not affect processing carried out on another lawful basis;
• May take a reasonable period to become effective across all communication systems; and
• Will not prevent AzariPay from sending essential service or legally required communications.

10. Protection Against Unauthorised Marketing

AzariPay implements appropriate administrative, technical, and organisational measures to ensure that marketing communications are sent responsibly and in accordance with applicable privacy and electronic communications laws.

If you believe you have received unauthorised marketing communications claiming to originate from AzariPay, please contact us immediately so that we can investigate and take appropriate action.

11. Changes to Your Preferences

You may review and update your communication and marketing preferences at any time through your AzariPay account settings or by contacting Customer Support.

AzariPay will make reasonable efforts to process preference updates promptly, although some communications already in progress may still be delivered.

12. Compliance with Applicable Law

All marketing activities conducted by AzariPay are subject to applicable data protection, consumer protection, advertising, electronic communications, and financial services laws and regulations. We are committed to ensuring that our marketing practices remain fair, transparent, respectful of customer choices, and consistent with the privacy principles set out in this Privacy Policy.

Customer Rights

1. Your Privacy Rights

At AzariPay Technologies Ltd (“AzariPay“, “we“, “our“, or “us“), we are committed to respecting your privacy and protecting your personal information. Subject to applicable law, you may exercise certain rights regarding the personal information we collect and process about you.

These rights may vary depending on your country of residence, the nature of the information, and the legal basis upon which we process it.

2. Right to Be Informed

You have the right to be informed about:

• The personal information we collect;
• The purposes for which we process your information;
• The legal basis for processing;
• The categories of recipients with whom we may share your information;
• How long we retain your information;
• Your available privacy rights; and
• How to contact us regarding privacy-related matters.

This Privacy Policy is intended to provide that information in a clear and transparent manner.

3. Right of Access

You may request confirmation as to whether AzariPay processes your personal information and, where applicable, request access to:

• The personal information we hold about you;
• The purposes of processing;
• The categories of information processed;
• The recipients or categories of recipients;
• The source of the information where it was not obtained directly from you; and
• Other information required under applicable law.

To protect your privacy and security, we may verify your identity before responding to an access request.

4. Right to Correction

If you believe that any personal information we hold about you is inaccurate, incomplete, or outdated, you may request that we correct or update it.

AzariPay may require supporting documentation before making certain changes, particularly where identity verification or regulatory records are involved.

5. Right to Erasure

Subject to applicable law, you may request that AzariPay delete or erase your personal information where:

• The information is no longer necessary for the purpose for which it was collected;
• Processing is based solely on your consent and you withdraw that consent;
• The information has been unlawfully processed; or
• Deletion is otherwise required by applicable law.

This right is not absolute. We may retain information where necessary to:

• Comply with legal or regulatory obligations;
• Meet financial services, AML, KYC, taxation, accounting, or audit requirements;
• Detect or prevent fraud;
• Complete outstanding transactions;
• Exercise or defend legal claims; or
• Protect the legitimate interests of AzariPay or third parties.

6. Right to Restrict Processing

Where permitted by applicable law, you may request that we restrict the processing of your personal information in circumstances such as:

• You contest the accuracy of the information;
• Processing is unlawful but you oppose deletion;
• We no longer require the information, but you need it for legal claims; or
• You object to processing while we consider your request.

During a restriction period, AzariPay may continue to retain the information and process it where legally permitted.

7. Right to Object

Where processing is based on our legitimate interests or carried out for direct marketing purposes, you may object to such processing.

AzariPay will carefully consider your objection and cease the processing where required by applicable law unless we demonstrate compelling legitimate grounds or have another lawful basis for continuing the processing.

8. Right to Withdraw Consent

Where we rely on your consent to process personal information, you may withdraw that consent at any time.

Withdrawal of consent:

• Does not affect processing already carried out before withdrawal;
• Does not affect processing based on another lawful basis;
• May limit your ability to use certain AzariPay services that depend on your consent; and
• Does not affect mandatory processing required by law.

9. Right to Data Portability

Where applicable law provides this right and it is technically feasible, you may request a copy of certain personal information you have provided to AzariPay in a structured, commonly used, and machine-readable format.

Where appropriate and technically feasible, you may also request that such information be transmitted directly to another service provider.

This right applies only where the processing is based on consent or contract and is carried out by automated means.

10. Rights Relating to Automated Decision-Making

Where AzariPay uses automated systems that produce legal or similarly significant effects, you may have the right, subject to applicable law, to:

• Request meaningful information about the automated process;
• Request human review of the decision;
• Present additional information relevant to the decision; and
• Challenge or contest the outcome where appropriate.

These rights may be limited where automated processing is authorised by law or necessary for fraud prevention, security, or regulatory compliance.

11. Right to Lodge a Complaint

If you believe that AzariPay has processed your personal information in violation of applicable data protection laws, you may:

• Contact AzariPay using the contact details provided in this Privacy Policy; and
• Lodge a complaint with the relevant data protection authority or other competent supervisory authority in your jurisdiction.

We encourage you to contact us first so that we have an opportunity to investigate and resolve your concerns promptly.

12. Verification of Requests

To protect your privacy and prevent unauthorised disclosure of personal information, AzariPay may require you to verify your identity before acting on any privacy request.

Where permitted by law, we may:

• Request additional identification documents;
• Ask security questions;
• Verify account ownership; or
• Take other reasonable steps to confirm your identity.

We may decline requests where we are unable to verify the identity or authority of the requester.

13. Limitations on Customer Rights

Your privacy rights are subject to applicable laws and may be limited where exercising those rights would:

• Prevent compliance with legal or regulatory obligations;
• Compromise fraud prevention, cybersecurity, or financial crime investigations;
• Reveal confidential commercial information or trade secrets;
• Infringe the rights or freedoms of another individual;
• Interfere with judicial or regulatory proceedings;
• Affect national security or public safety; or
• Otherwise be restricted by applicable law.

Where we are unable to comply fully with a request, we will explain the reason unless prohibited by law.

14. Exercising Your Rights

You may exercise your privacy rights by contacting AzariPay through the official customer support channels or our designated Data Protection Officer using the contact information provided in this Privacy Policy.

We will acknowledge and respond to requests within the timeframes required by applicable law. In certain circumstances, we may extend the response period where permitted by law, particularly where requests are complex or numerous.

AzariPay reserves the right to decline requests that are manifestly unfounded, repetitive, excessive, fraudulent, or otherwise not required under applicable law.

15. No Retaliation

AzariPay will not unlawfully discriminate against or retaliate against you for exercising your privacy rights. However, where the exercise of a particular right makes it impossible for us to continue providing a service or to comply with our legal obligations, we may suspend, limit, or terminate the affected service in accordance with our Terms and Conditions and applicable law.

Children’s Privacy

1. Our Commitment to Protecting Children

AzariPay Technologies Ltd (“AzariPay“, “we“, “our“, or “us“) recognises the importance of protecting the privacy and personal information of children. We are committed to complying with all applicable laws and regulations governing the processing of children’s personal information and implementing appropriate safeguards where such information is collected or processed.

2. Services Intended for Adults

Unless expressly stated otherwise, AzariPay’s products and services are intended for individuals who have reached the legal age required to enter into a binding contract and operate a financial account under applicable law.

We do not knowingly market our services directly to children or intentionally collect personal information from children except where permitted by applicable law and subject to appropriate safeguards.

3. Collection of Children’s Personal Information

AzariPay may collect personal information relating to a child only where:

• It is required by applicable law;
• A parent or legal guardian has provided the necessary consent where required;
• The child is the beneficiary of an account or service lawfully established by a parent or legal guardian;
• The processing is necessary to provide a product or service specifically designed for children; or
• Processing is otherwise authorised or required under applicable law.

The categories of information collected will be limited to what is reasonably necessary for the specific purpose.

4. Parental or Guardian Consent

Where consent is required for the processing of a child’s personal information, AzariPay will take reasonable steps to verify that such consent has been provided by the child’s parent or lawful guardian before processing the information.

AzariPay reserves the right to request documentation or other evidence confirming parental or guardian authority where necessary.

5. Use of Children’s Personal Information

Where lawfully collected, children’s personal information may be used only for purposes including:

• Establishing or administering an authorised account or service;
• Identity verification where appropriate;
• Providing requested financial services;
• Meeting legal and regulatory obligations;
• Protecting the safety and security of the child and our services;
• Preventing fraud and financial crime; and
• Any other purpose authorised by applicable law or parental consent.

AzariPay does not knowingly use children’s personal information for behavioural advertising or profiling that is prohibited by applicable law.

6. Sharing Children’s Personal Information

Children’s personal information may be disclosed only where necessary to:

• Provide requested services;
• Comply with legal or regulatory obligations;
• Protect the rights, safety, or security of the child or others;
• Prevent fraud or unlawful activity;
• Respond to lawful requests from competent authorities; or
• Other recipients authorised by applicable law or parental consent.

Such disclosures will be limited to the minimum information reasonably necessary for the relevant purpose.

7. Security of Children’s Information

AzariPay applies the same high standard of technical, organisational, and administrative safeguards to children’s personal information as it does to all personal information. Where appropriate, we may apply additional protections based on the sensitivity of the information and applicable legal requirements.

8. Retention of Children’s Personal Information

Children’s personal information will be retained only for as long as necessary to fulfil the purpose for which it was collected or to comply with applicable legal, regulatory, accounting, or record-keeping obligations. When no longer required, the information will be securely deleted, destroyed, or irreversibly anonymised in accordance with our Data Retention Policy.

9. Rights of Parents and Legal Guardians

Subject to applicable law, parents or legal guardians may request to:

• Access personal information relating to their child;
• Correct inaccurate or incomplete information;
• Withdraw consent where consent is the legal basis for processing;
• Request deletion of the child’s personal information, subject to legal and regulatory retention obligations;
• Restrict or object to certain processing activities where permitted by law; and
• Raise concerns or complaints regarding the processing of their child’s personal information.

AzariPay may require reasonable verification of the identity and authority of the requesting parent or legal guardian before acting on such requests.

10. Unintentional Collection of Children’s Information

If AzariPay becomes aware that we have collected personal information from a child without the required legal basis or parental consent where required, we will take reasonable steps to:

• Verify the circumstances of the collection;
• Obtain the necessary consent where appropriate; or
• Delete the information as soon as reasonably practicable, unless retention is required by applicable law.

Parents or legal guardians who believe that a child has provided personal information to AzariPay without appropriate authorisation are encouraged to contact us promptly.

11. Future Child-Focused Services

If AzariPay introduces products or services specifically designed for children or young persons in the future, we may publish additional privacy notices or policies that supplement this Privacy Policy and provide further information regarding the collection, use, disclosure, and protection of children’s personal information.

12. Compliance with Applicable Law

AzariPay processes children’s personal information in accordance with applicable data protection, consumer protection, financial services, and child protection laws. We will periodically review our practices to ensure they remain consistent with evolving legal requirements, regulatory guidance, and recognised best practices for protecting children’s privacy.

Automated Decision-Making

1. Use of Automated Decision-Making

AzariPay Technologies Ltd (“AzariPay“, “we“, “our“, or “us“) uses automated technologies to enhance the security, efficiency, reliability, and integrity of our products and services. These technologies assist us in processing transactions, detecting fraud, managing risk, complying with legal and regulatory obligations, improving customer experience, and protecting our customers and business.

Automated processing is used as a decision-support tool and, where appropriate, may contribute to decisions affecting the provision of our services.

2. Technologies We May Use

AzariPay may use a combination of automated technologies, including:

• Artificial Intelligence (AI);
• Machine Learning (ML);
• Rule-based decision engines;
• Behavioural analytics;
• Fraud detection systems;
• Risk scoring models;
• Identity verification technologies;
• Device intelligence tools;
• Transaction monitoring systems;
• Cybersecurity and threat detection solutions; and
• Other automated technologies that support our operations and legal obligations.

These technologies are regularly reviewed and refined to improve their effectiveness, accuracy, and fairness.

3. Purposes of Automated Processing

Automated processing may be used to:

• Verify customer identities;
• Authenticate login attempts;
• Detect suspicious or unusual activity;
• Prevent fraud, money laundering, terrorist financing, sanctions violations, and other financial crimes;
• Assess transaction and account risk;
• Detect account compromise or unauthorised access;
• Identify duplicate or potentially fraudulent accounts;
• Improve transaction processing efficiency;
• Personalise customer experiences where appropriate;
• Enhance cybersecurity;
• Monitor compliance with applicable laws and regulations;
• Improve service performance; and
• Support operational decision-making.

4. Decisions That May Be Influenced by Automated Processing

Automated processing may contribute to decisions such as:

• Approving or declining account registration pending further verification;
• Requesting additional identity verification;
• Flagging transactions for review;
• Delaying or declining high-risk transactions;
• Applying temporary security restrictions;
• Identifying suspicious activity for manual investigation;
• Triggering fraud prevention measures;
• Requiring enhanced customer due diligence;
• Determining eligibility for certain products or features; and
• Prioritising customer support or security responses.

In many cases, automated processing supports human decision-making rather than replacing it.

5. Human Oversight

AzariPay recognises that automated technologies may not always produce perfect outcomes. Where decisions are likely to have legal or similarly significant effects on an individual, we implement appropriate safeguards, which may include:

• Human review by authorised personnel;
• Additional verification procedures;
• Internal escalation processes;
• Opportunities for customers to provide additional information; and
• Review mechanisms where required by applicable law.

6. Fairness and Responsible Use

AzariPay is committed to using automated technologies responsibly. We take reasonable measures to:

• Test automated systems for accuracy and reliability;
• Monitor system performance;
• Reduce the risk of inappropriate bias;
• Maintain data quality;
• Review significant decision-making processes;
• Apply appropriate governance and oversight; and
• Improve automated models over time based on operational experience and legal requirements.

7. Information Used by Automated Systems

Automated systems may analyse information including:

• Identity verification information;
• Transaction history;
• Device and technical information;
• Login and authentication records;
• Account activity;
• Security indicators;
• Fraud detection signals;
• Customer risk profiles;
• Behavioural patterns;
• Geographic and network information where appropriate; and
• Other information lawfully collected under this Privacy Policy.

Automated systems are designed to process only information reasonably necessary for the relevant purpose.

8. Your Rights

Subject to applicable law, where an automated decision produces legal or similarly significant effects, you may have the right to:

• Request information about the decision-making process;
• Request that the decision be reviewed by an authorised person;
• Provide additional information relevant to the decision;
• Challenge or contest the outcome where appropriate; and
• Exercise any other rights available under applicable data protection laws.

These rights may be limited where processing is authorised by law or necessary for fraud prevention, financial crime compliance, cybersecurity, or other overriding legal obligations.

9. Continuous Monitoring and Improvement

AzariPay regularly evaluates and improves its automated systems to ensure they remain secure, effective, proportionate, and aligned with applicable legal and regulatory requirements. This may include periodic testing, validation, performance monitoring, model updates, and governance reviews.

10. No Sole Reliance Where Prohibited by Law

Where applicable law prohibits decisions based solely on automated processing without appropriate safeguards, AzariPay will ensure that such decisions are subject to meaningful human involvement or other legally required protections before a final decision is made.

11. Customer Acknowledgement

By using AzariPay’s products and services, you acknowledge that AzariPay may use automated technologies to process your personal information for the purposes described in this Privacy Policy. Such processing will be carried out in accordance with applicable law, with appropriate technical and organisational safeguards, and with due regard to your rights and legitimate interests.

Third-Party Services

1. Our Use of Third-Party Services

AzariPay Technologies Ltd (“AzariPay“, “we“, “our“, or “us“) works with carefully selected third-party service providers, technology partners, financial institutions, and other organisations to enable us to provide secure, efficient, innovative, and reliable financial services.

These third parties may process personal information on our behalf or receive limited information where necessary to deliver the products and services you request or to support our business operations.

2. Categories of Third-Party Service Providers

Depending on the products and services you use, AzariPay may engage third parties providing services including:

• Banking and settlement services;
• Payment processing and payment gateways;
• Card issuing, card processing, and payment network services;
• Foreign exchange and cross-border payment services;
• Identity verification and electronic KYC services;
• Fraud prevention, cybersecurity, and risk management services;
• Cloud hosting and data storage;
• Disaster recovery and business continuity services;
• Software development and technology infrastructure;
• Customer support and communication platforms;
• Analytics and performance monitoring;
• Email, SMS, push notification, and messaging services;
• Merchant acquiring and business payment solutions;
• Regulatory reporting and compliance services;
• Accounting, auditing, legal, and professional advisory services;
• Marketing and customer engagement platforms, where permitted by law; and
• Other service providers reasonably necessary for the operation and improvement of AzariPay’s services.

3. Information Shared with Third Parties

Where necessary, AzariPay may share personal information with third-party service providers, including:

• Identity verification information;
• Contact information;
• Account information;
• Transaction information;
• Device and technical information;
• Authentication and security information;
• Customer support records;
• Compliance-related information; and
• Other information reasonably necessary for the relevant service.

We disclose only the minimum amount of information reasonably required for the specific purpose.

4. Our Expectations of Third Parties

Before engaging a third-party service provider that processes personal information on our behalf, AzariPay takes reasonable steps to ensure that the provider:

• Maintains appropriate technical and organisational security measures;
• Complies with applicable privacy and data protection laws;
• Processes personal information only on AzariPay’s documented instructions;
• Maintains strict confidentiality obligations;
• Restricts access to authorised personnel;
• Implements appropriate cybersecurity controls;
• Notifies AzariPay of relevant security incidents where required;
• Assists AzariPay in meeting applicable legal obligations where appropriate; and
• Securely returns or deletes personal information at the end of the engagement where applicable.

5. Third-Party Websites and Applications

Our website, mobile applications, or communications may contain links to third-party websites, applications, products, or services that are not owned, operated, or controlled by AzariPay.

These third parties operate independently and maintain their own privacy policies, terms of use, and security practices.

AzariPay does not control and is not responsible for:

• The privacy practices of third parties;
• The security of third-party platforms;
• The content of third-party websites or applications;
• Information collected directly by third parties; or
• The availability or reliability of third-party services.

You are encouraged to review the privacy policies and terms of any third-party service before providing your personal information.

6. Third-Party Payment and Financial Networks

Transactions processed through AzariPay may involve third-party financial institutions, payment schemes, correspondent banks, card networks, settlement providers, and payment infrastructure operators.

These organisations may collect, process, or retain certain information as required to:

• Process transactions;
• Verify payment instructions;
• Prevent fraud;
• Meet legal and regulatory obligations;
• Resolve disputes;
• Manage chargebacks; and
• Maintain the integrity of payment systems.

Such processing is governed by their own legal and regulatory obligations in addition to any contractual arrangements with AzariPay.

7. International Third-Party Providers

Some of our service providers may be located outside your country of residence.

Where personal information is transferred internationally to third-party providers, AzariPay implements appropriate contractual, technical, and organisational safeguards consistent with applicable data protection laws and our International Data Transfers policy.

8. Changes to Third-Party Providers

AzariPay may add, replace, or discontinue third-party service providers as our business, technology, regulatory requirements, or customer needs evolve.

Any such changes will be managed in accordance with this Privacy Policy and applicable law.

9. Limitation of Responsibility

While AzariPay exercises reasonable care in selecting and overseeing third-party service providers, we cannot guarantee the security, availability, accuracy, or privacy practices of independent third parties that are outside our direct control.

To the fullest extent permitted by applicable law, AzariPay shall not be liable for any loss, damage, delay, unauthorised disclosure, service interruption, or other harm arising solely from the acts, omissions, failures, or security incidents of independent third-party providers, provided that AzariPay has exercised reasonable care in selecting such providers and has complied with its applicable legal obligations.

Nothing in this section limits any liability that cannot lawfully be excluded under applicable law.

10. Customer Acknowledgement

By accessing or using AzariPay’s products and services, you acknowledge and agree that AzariPay may engage trusted third-party service providers to support the delivery, operation, security, compliance, and improvement of our services.

You further acknowledge that, where necessary to provide the services you request or comply with applicable law, AzariPay may disclose relevant personal information to such third parties, subject to appropriate contractual, technical, and organisational safeguards designed to protect your information.

Azari Select & Concierge Services

1. Overview

Azari Select is the premium lifestyle, privileges, rewards, and concierge ecosystem offered by AzariPay Technologies Ltd (“AzariPay“, “we“, “our“, or “us“). It is designed to complement your AzariPay experience by providing access to exclusive offers, premium services, luxury experiences, merchant benefits, and concierge assistance through AzariPay and selected partners.

Participation in Azari Select is subject to this Privacy Policy, our Terms and Conditions, and any additional programme terms that may apply.

2. Membership

Unless otherwise stated, eligible AzariPay Wallet users may automatically be enrolled in Azari Select or become eligible through participation in qualifying products or services.

Your membership may include access to benefits such as:

• Concierge assistance;
• Merchant discounts and exclusive offers;
• Travel and lifestyle privileges;
• Hotel, dining, and entertainment benefits;
• Airport lounge access where available;
• Event invitations and premium experiences;
• Luxury shopping privileges;
• Wellness and healthcare partner benefits;
• Business networking opportunities;
• Rewards, promotions, and exclusive campaigns; and
• Other benefits introduced by AzariPay from time to time.

Membership eligibility, benefits, and availability may vary by jurisdiction, product, regulatory requirements, and commercial partnerships.

3. Information We Collect

To deliver Azari Select services effectively, AzariPay may collect and process information including:

• Your AzariPay account information;
• Contact details;
• Membership status;
• Communication preferences;
• Lifestyle and service preferences voluntarily provided by you;
• Travel preferences;
• Booking requests;
• Event registrations;
• Merchant interactions;
• Reward redemption history;
• Concierge service requests;
• Customer support communications;
• Transaction information relevant to requested services; and
• Other information reasonably necessary to fulfil your requests.

We collect only the information reasonably necessary for the requested service.

4. Concierge Services

AzariPay may provide concierge services directly or through carefully selected third-party concierge providers.

Concierge assistance may include:

• Travel planning and reservations;
• Hotel bookings;
• Restaurant reservations;
• Flight assistance;
• Ground transportation arrangements;
• Event ticket sourcing;
• Luxury lifestyle recommendations;
• Gift procurement;
• Personal shopping assistance;
• Business support services;
• Corporate hospitality;
• Emergency travel assistance referrals;
• Lifestyle management; and
• Other concierge services made available by AzariPay.

Concierge services are provided on a reasonable-efforts basis and remain subject to availability, applicable law, third-party capacity, and operational constraints.

5. Sharing Information with Concierge and Lifestyle Partners

Where necessary to fulfil your request, AzariPay may share relevant personal information with trusted concierge providers, hotels, airlines, merchants, restaurants, event organisers, transportation providers, healthcare providers, luxury brands, or other service partners.

Information shared may include:

• Name;
• Contact information;
• Reservation details;
• Travel information;
• Booking preferences;
• Loyalty programme details where applicable;
• Special requests voluntarily provided by you;
• Payment confirmation where necessary; and
• Other information reasonably required to deliver the requested service.

Only the minimum information reasonably necessary will be shared.

6. Personalisation of Benefits

To enhance your experience, AzariPay may personalise Azari Select services based on:

• Products and services you use;
• Transaction history;
• Previous concierge requests;
• Membership activity;
• Reward redemption history;
• Geographic location where appropriate;
• Language preferences;
• Communication preferences;
• Customer feedback; and
• Other information processed in accordance with this Privacy Policy.

Personalisation is intended to improve the relevance, quality, and convenience of the services we provide.

7. Marketing and Exclusive Offers

Azari Select members may receive information regarding:

• Exclusive promotions;
• Luxury brand collaborations;
• Merchant discounts;
• Partner offers;
• Concierge services;
• Travel experiences;
• Premium events;
• Reward campaigns;
• Lifestyle recommendations; and
• Other member benefits.

Marketing communications remain subject to your communication preferences and the Marketing Preferences section of this Privacy Policy.

8. Third-Party Providers

Many Azari Select benefits are delivered through independent third-party partners.

While AzariPay carefully selects its partners, we do not own or control their businesses or operations.

Each partner remains independently responsible for:

• The products or services they provide;
• Their own privacy practices;
• Service quality;
• Pricing;
• Availability;
• Warranties;
• Consumer obligations; and
• Compliance with applicable law.

You may also become subject to the partner’s own terms and privacy policies when using their services.

9. Payments for Concierge Services

Certain concierge services, reservations, purchases, bookings, memberships, or premium experiences may require payment.

Where payment is required:

• Applicable charges will be communicated where reasonably practicable before confirmation;
• Payment may be processed through AzariPay or an authorised payment provider;
• Additional taxes, duties, gratuities, service charges, or third-party fees may apply;
• Cancellation and refund policies may vary depending on the service provider; and
• AzariPay is not responsible for pricing determined by independent third-party providers.

10. Availability of Benefits

Azari Select benefits are offered subject to:

• Availability;
• Geographic coverage;
• Merchant participation;
• Partner capacity;
• Regulatory restrictions;
• Security considerations;
• Operational requirements; and
• Force majeure events.

AzariPay does not guarantee the continuous availability of any specific benefit, partner, offer, or concierge service.

We reserve the right to introduce, modify, suspend, substitute, or discontinue any Azari Select feature, benefit, partnership, or programme at any time, with or without prior notice where permitted by applicable law.

11. Data Security

Personal information collected in connection with Azari Select is protected using the same technical, administrative, and organisational safeguards described in the Data Security section of this Privacy Policy.

Where information is shared with authorised partners, AzariPay requires such partners to implement appropriate measures to safeguard personal information consistent with applicable law and contractual obligations.

12. Limitation of Responsibility

AzariPay acts as a facilitator of many Azari Select benefits and concierge arrangements.

Except where otherwise required by applicable law, AzariPay does not warrant or guarantee:

• The availability of third-party services;
• The quality or suitability of products supplied by partners;
• Reservations made by independent providers;
• Travel schedules;
• Hotel accommodations;
• Event availability;
• Merchant inventory;
• Lifestyle services; or
• Other services delivered by independent third parties.

To the fullest extent permitted by law, AzariPay shall not be liable for losses, delays, cancellations, service failures, injuries, damages, or disputes arising directly from the acts or omissions of independent third-party providers.

Nothing in this section excludes or limits liability that cannot lawfully be excluded.

13. Future Expansion

As AzariPay expands internationally, Azari Select may introduce additional benefits, premium memberships, concierge offerings, merchant partnerships, rewards programmes, travel services, and lifestyle experiences across different countries and regions.

Any new offerings will be governed by this Privacy Policy together with any supplementary terms published by AzariPay.

14. Customer Acknowledgement

By participating in Azari Select or requesting concierge services, you acknowledge and agree that AzariPay may process and, where necessary, share your personal information with authorised partners solely for the purpose of delivering the requested services, benefits, rewards, reservations, and experiences.

You further acknowledge that many Azari Select benefits are provided by independent third-party organisations, and your use of those services may also be governed by their respective terms, conditions, and privacy policies.

Business Customers

1. Overview

AzariPay Technologies Ltd (“AzariPay“, “we“, “our“, or “us“) provides financial technology solutions and related services to businesses of various sizes, including sole proprietorships, partnerships, companies, non-governmental organisations, charities, educational institutions, financial institutions, government entities, and other organisations (collectively, “Business Customers“).

This section explains how we collect, use, disclose, and protect personal information in connection with our business products and services.

2. Information We Collect

In addition to the personal information described elsewhere in this Privacy Policy, AzariPay may collect and process information relating to Business Customers, including:

• Business name and trading name;
• Business registration and incorporation details;
• Tax identification numbers and regulatory licences;
• Registered and operational business addresses;
• Contact information for directors, officers, shareholders, beneficial owners, authorised signatories, employees, agents, and representatives;
• Identity verification and Know Your Customer (KYC) information;
• Know Your Business (KYB) documentation;
• Ultimate Beneficial Owner (UBO) information where required;
• Banking and settlement information;
• Transaction and payment records;
• Merchant and commercial activity information;
• Financial statements and supporting documentation where required;
• Compliance, sanctions, and screening information;
• Device, technical, and security information; and
• Any other information reasonably necessary to establish, administer, or support the business relationship.

3. Purposes of Processing

AzariPay may process Business Customer information for purposes including:

• Establishing and maintaining business accounts;
• Conducting KYC, KYB, and customer due diligence;
• Verifying directors, beneficial owners, and authorised representatives;
• Processing domestic and international payments;
• Supporting merchant services and business banking features;
• Preventing fraud, money laundering, terrorist financing, sanctions evasion, and other financial crimes;
• Meeting legal and regulatory obligations;
• Providing customer support and relationship management;
• Managing settlements, reconciliation, and reporting;
• Monitoring account activity and service usage;
• Improving products and services;
• Managing contractual relationships;
• Protecting AzariPay’s legal rights and business interests; and
• Any other compatible purpose permitted by applicable law.

4. Authorised Representatives

Business Customers may appoint authorised representatives to act on their behalf.

By providing the personal information of directors, employees, shareholders, beneficial owners, or other representatives, the Business Customer confirms that it:

• Has the legal authority to provide such information;
• Has informed those individuals of the disclosure where required;
• Has obtained any necessary consents or authorisations required by applicable law; and
• Is authorised to instruct AzariPay regarding the administration of the business account.

AzariPay may rely on instructions received from authorised representatives until notified otherwise through approved procedures.

5. Compliance and Due Diligence

Business Customers may be required to undergo ongoing due diligence throughout the business relationship.

AzariPay may request updated information or documentation relating to:

• Corporate ownership;
• Directors and officers;
• Beneficial ownership;
• Business activities;
• Source of funds;
• Source of wealth where applicable;
• Regulatory licences;
• Tax information;
• Financial records; and
• Other compliance-related information required by applicable law.

Failure to provide requested information may result in delayed onboarding, restricted services, suspension, or termination of the business relationship where permitted by law.

6. Business Transactions

AzariPay may process information relating to:

• Customer payments;
• Supplier payments;
• Payroll processing;
• Merchant settlements;
• International transfers;
• Foreign exchange transactions;
• Card payments;
• API transactions;
• Subscription payments;
• Invoice payments;
• Collection services; and
• Other commercial transactions supported by our platform.

Transaction records may be retained for legal, regulatory, audit, taxation, security, and fraud prevention purposes.

7. Sharing Business Information

AzariPay may disclose Business Customer information where necessary to:

• Banking partners;
• Payment processors;
• Card schemes;
• Settlement institutions;
• Identity verification providers;
• Compliance and screening providers;
• Cloud and technology service providers;
• Professional advisers;
• Regulators, law enforcement agencies, and competent authorities;
• Auditors;
• Insurance providers where appropriate;
• Collection or recovery agents where lawfully engaged; and
• Other authorised third parties necessary to provide our services or comply with legal obligations.

Only the minimum information reasonably necessary will be disclosed for the relevant purpose.

8. Employee and Representative Information

Where a Business Customer provides information relating to its employees, contractors, directors, officers, shareholders, or representatives, AzariPay processes such information solely to:

• Administer business accounts;
• Authenticate authorised users;
• Manage permissions and account access;
• Conduct compliance screening;
• Provide requested services;
• Maintain account security; and
• Meet legal and regulatory obligations.

The Business Customer remains responsible for ensuring that it has an appropriate legal basis for providing such information to AzariPay.

9. International Business Operations

Where Business Customers engage in international transactions or use AzariPay’s cross-border services, personal information may be transferred to financial institutions, payment partners, regulators, correspondent banks, or service providers located in other jurisdictions.

Such transfers will be carried out in accordance with the International Data Transfers section of this Privacy Policy and applicable data protection laws.

10. Business Communications

AzariPay may send Business Customers operational and administrative communications, including:

• Service notifications;
• Security alerts;
• Regulatory updates;
• Compliance requests;
• Account statements;
• Transaction confirmations;
• Product enhancements;
• Technical notices;
• Maintenance notifications; and
• Other communications necessary to manage the business relationship.

Marketing communications remain subject to applicable law and the Business Customer’s communication preferences.

11. Business Analytics

AzariPay may analyse aggregated or anonymised business data to:

• Improve our products and services;
• Enhance platform performance;
• Develop new business solutions;
• Produce statistical reports;
• Monitor system usage;
• Strengthen fraud prevention;
• Assess operational performance; and
• Support strategic planning.

Such analytics will not identify individual Business Customers or natural persons unless required for legitimate operational or regulatory purposes.

12. Business Customer Responsibilities

Business Customers are responsible for:

• Providing accurate and up-to-date information;
• Promptly notifying AzariPay of changes to authorised representatives or ownership;
• Protecting account credentials and access permissions;
• Complying with applicable laws and regulations;
• Ensuring that personal information shared with AzariPay has been lawfully obtained; and
• Cooperating with reasonable compliance and security requests.

13. Termination of the Business Relationship

Where a Business Customer closes its account or the relationship otherwise ends, AzariPay may continue to retain relevant information for the periods required to:

• Comply with legal and regulatory obligations;
• Meet financial reporting and taxation requirements;
• Resolve disputes;
• Prevent fraud;
• Exercise or defend legal claims;
• Conduct audits; and
• Protect AzariPay’s legitimate business interests.

Retention and secure disposal will be carried out in accordance with the Data Retention section of this Privacy Policy.

14. Customer Acknowledgement

By opening or using a Business Account with AzariPay, the Business Customer acknowledges and agrees that AzariPay may collect, use, disclose, transfer, retain, and otherwise process business-related personal information as described in this Privacy Policy, where necessary to provide services, fulfil contractual obligations, protect the security and integrity of our platform, and comply with applicable laws and regulatory requirements.

Cross-Border Payments

1. Overview

AzariPay Technologies Ltd (“AzariPay“, “we“, “our“, or “us“) provides cross-border payment solutions that enable individuals and businesses to send, receive, settle, and manage international financial transactions. In delivering these services, we may collect, use, disclose, transfer, and retain personal information in accordance with this Privacy Policy, our Terms and Conditions, and applicable laws and regulations.

Cross-border payment services may be offered directly by AzariPay or in collaboration with licensed financial institutions, correspondent banks, payment processors, foreign exchange providers, card schemes, payment networks, or other authorised partners.

2. Information We Collect

To facilitate cross-border payments, AzariPay may collect and process information including:

• Sender and recipient names;
• Contact information;
• Residential or business addresses where required;
• Date of birth where required by law;
• Government-issued identification details;
• Know Your Customer (KYC) and Know Your Business (KYB) documentation;
• Ultimate Beneficial Owner (UBO) information where applicable;
• Banking and payment account details;
• Wallet identifiers;
• International bank account information;
• Payment references and transaction descriptions;
• Source of funds and source of wealth information where required;
• Foreign exchange preferences;
• Transaction amounts and currencies;
• Device and technical information;
• Risk assessment information; and
• Other information reasonably required to process international transactions or comply with legal obligations.

3. Purposes of Processing

AzariPay processes personal information relating to cross-border payments for purposes including:

• Executing international payment instructions;
• Receiving international transfers;
• Processing currency conversion and foreign exchange transactions;
• Verifying customer identity and payment instructions;
• Conducting sanctions, AML, CTF, PEP, and other regulatory screening;
• Preventing fraud and financial crime;
• Managing payment routing and settlement;
• Monitoring transaction risk;
• Resolving disputes, recalls, and investigations;
• Complying with legal and regulatory obligations;
• Providing customer support; and
• Improving the efficiency, security, and reliability of our international payment services.

4. International Information Sharing

Cross-border payments often require AzariPay to disclose relevant information to third parties located in multiple jurisdictions.

Depending on the transaction, information may be shared with:

• Correspondent banks;
• Receiving and intermediary financial institutions;
• Licensed payment service providers;
• Card schemes and payment networks;
• Foreign exchange providers;
• Clearing and settlement systems;
• Regulatory authorities;
• Financial intelligence units;
• Law enforcement agencies where legally required;
• Sanctions screening providers;
• Identity verification providers; and
• Other organisations reasonably necessary to complete the transaction.

Only information reasonably necessary for the relevant purpose will be disclosed.

5. Cross-Border Data Transfers

Because international payments involve multiple financial institutions operating in different countries, your personal information may be transferred to, processed in, or accessed from jurisdictions outside your country of residence.

Such transfers may occur even where the destination jurisdiction provides a different level of data protection than your home jurisdiction.

Where required by applicable law, AzariPay implements appropriate contractual, technical, and organisational safeguards to protect personal information during international transfers.

Further information is provided in the International Data Transfers section of this Privacy Policy.

6. Regulatory Compliance

AzariPay is required to comply with applicable domestic and international laws relating to cross-border financial transactions.

Accordingly, we may process personal information to:

• Conduct sanctions screening;
• Verify identities;
• Monitor suspicious transactions;
• Report transactions to competent authorities;
• Comply with anti-money laundering (AML), counter-terrorist financing (CTF), anti-proliferation financing (CPF), anti-bribery, tax reporting, and other regulatory obligations;
• Respond to lawful requests from regulators or courts; and
• Meet record-keeping requirements.

Certain transactions may be delayed, rejected, suspended, or cancelled where required by applicable law or regulatory obligations.

7. Foreign Exchange Services

Where currency conversion forms part of a transaction, AzariPay may process information necessary to:

• Obtain exchange rates;
• Execute foreign exchange conversions;
• Calculate fees and charges;
• Confirm settlement instructions;
• Maintain transaction records; and
• Meet applicable regulatory and accounting requirements.

Exchange rates and foreign exchange services may be provided directly by AzariPay or through authorised third-party providers.

8. Security and Fraud Prevention

International transactions are subject to enhanced fraud prevention, cybersecurity, and transaction monitoring measures.

AzariPay may use automated systems and human review to:

• Detect unusual transaction patterns;
• Assess transaction risk;
• Identify potential account compromise;
• Prevent unauthorised transactions;
• Verify payment instructions;
• Monitor device behaviour;
• Detect financial crime; and
• Protect customers and payment networks.

These activities are carried out in accordance with the Fraud Prevention & AML Compliance, Automated Decision-Making, and Data Security sections of this Privacy Policy.

9. Transaction Delays and Investigations

Cross-border payments may be delayed, suspended, recalled, investigated, rejected, or cancelled due to:

• Regulatory screening;
• Compliance reviews;
• Security concerns;
• Incorrect payment information;
• Sanctions or watchlist matches;
• Requests from financial institutions;
• Fraud investigations;
• Technical or operational issues; or
• Other circumstances beyond AzariPay’s reasonable control.

AzariPay will make reasonable efforts to assist customers in resolving payment issues where practicable but cannot guarantee processing times for international payment systems operated by third parties.

10. Retention of Cross-Border Payment Records

AzariPay retains records relating to cross-border transactions for the periods required by applicable financial services, anti-money laundering, taxation, accounting, audit, and other legal or regulatory requirements.

Such records may continue to be retained even after an account has been closed where required by law or necessary to protect AzariPay’s legitimate interests.

11. Limitation of Responsibility

While AzariPay uses reasonable care in facilitating international payments, cross-border transactions depend on independent financial institutions, payment infrastructures, foreign exchange providers, telecommunications networks, regulators, and other third parties operating across multiple jurisdictions.

Accordingly, AzariPay does not guarantee:

• Continuous availability of international payment services;
• Processing times;
• Exchange rate availability;
• Acceptance of payment instructions by third parties;
• Availability of foreign financial institutions; or
• The uninterrupted operation of international payment networks.

To the fullest extent permitted by applicable law, AzariPay shall not be liable for delays, interruptions, exchange rate fluctuations, regulatory actions, correspondent banking decisions, intermediary deductions, sanctions restrictions, force majeure events, or other matters outside its reasonable control.

Nothing in this section excludes or limits liability that cannot lawfully be excluded.

12. Customer Responsibilities

Customers using AzariPay’s cross-border payment services are responsible for:

• Providing complete and accurate payment instructions;
• Ensuring recipient information is correct;
• Complying with applicable exchange control, sanctions, tax, and financial regulations;
• Providing supporting documentation where requested;
• Ensuring the lawful source and purpose of funds;
• Promptly reporting unauthorised or suspicious transactions; and
• Cooperating with reasonable compliance and verification requests.

Failure to provide requested information may result in delays, suspension, cancellation, or rejection of a transaction where permitted by law.

13. Customer Acknowledgement

By initiating or receiving a cross-border payment through AzariPay, you acknowledge and agree that your personal information may be collected, processed, transferred, retained, and disclosed to authorised financial institutions, payment partners, regulators, and other relevant parties across multiple jurisdictions where necessary to execute your transaction, comply with legal and regulatory obligations, safeguard the integrity of the financial system, and provide the requested services.

You further acknowledge that international payment processing is subject to the laws, regulations, operational procedures, and compliance requirements of the jurisdictions and financial institutions involved in the transaction.

Changes to this Privacy Policy

1. Our Right to Update This Privacy Policy

AzariPay Technologies Ltd (“AzariPay“, “we“, “our“, or “us“) may amend, revise, update, or replace this Privacy Policy from time to time to reflect changes in our business operations, products, services, technologies, legal obligations, regulatory requirements, industry standards, security practices, or other operational needs.

We encourage you to review this Privacy Policy periodically to remain informed about how we collect, use, disclose, and protect your personal information.

2. Reasons for Changes

We may update this Privacy Policy for reasons including, but not limited to:

• Introducing new products, services, or features;
• Expanding into new countries or jurisdictions;
• Changes to applicable laws, regulations, or regulatory guidance;
• Changes in data protection or privacy requirements;
• Improvements to our security practices;
• Adoption of new technologies, including artificial intelligence and automated systems;
• Changes to our business operations or corporate structure;
• Changes to third-party service providers or business partners;
• Enhancements to customer rights or privacy protections; or
• Clarifications, corrections, or improvements to this Privacy Policy.

3. Notification of Changes

Where required by applicable law, AzariPay will take reasonable steps to notify you of material changes to this Privacy Policy through one or more appropriate channels, which may include:

• Notices within the AzariPay mobile application;
• Website announcements;
• Email notifications;
• SMS notifications;
• Push notifications;
• Updates through your online account;
• Customer support communications; or
• Any other communication channel we reasonably consider appropriate.

For minor updates that do not materially affect your rights or the way we process your personal information, we may update this Privacy Policy without providing individual notice.

4. Effective Date

Each version of this Privacy Policy will display its effective date and, where appropriate, the date of the most recent revision.

The updated Privacy Policy becomes effective on the date specified unless a different effective date is required by applicable law.

5. Continued Use of Our Services

To the extent permitted by applicable law, your continued access to or use of AzariPay’s products and services after the effective date of an updated Privacy Policy constitutes your acknowledgement of the revised Privacy Policy.

Where applicable law requires your express consent for particular changes, AzariPay will obtain such consent before implementing those changes.

6. Historical Versions

AzariPay may retain previous versions of this Privacy Policy for legal, regulatory, audit, compliance, operational, or historical purposes.

Where appropriate, previous versions may be made available upon reasonable request or through other channels determined by AzariPay, subject to applicable law and internal record retention policies.

7. Material Changes Affecting Your Rights

If a change materially affects your privacy rights, significantly alters how we process your personal information, or requires additional consent under applicable law, AzariPay will provide notice and, where legally required, obtain your consent before such changes take effect.

8. Questions About Changes

If you have any questions regarding this Privacy Policy or any updates made to it, you may contact AzariPay using the contact information provided in the Contact Us section of this Privacy Policy.

We will make reasonable efforts to respond to privacy-related enquiries in accordance with applicable law.

9. Governing Version

This Privacy Policy, as amended from time to time, constitutes the current and authoritative statement of AzariPay’s privacy practices.

In the event of any inconsistency between previous versions and the current version, the current version shall prevail from its effective date, except where otherwise required by applicable law.

Contact Information

1. Contact Us

If you have any questions, concerns, requests, or complaints regarding this Privacy Policy or the way AzariPay Technologies Ltd (“AzariPay“, “we“, “our“, or “us“) collects, uses, discloses, stores, or otherwise processes your personal information, we encourage you to contact us using the details below.

We are committed to responding to privacy-related enquiries promptly, professionally, and in accordance with applicable data protection laws.

2. Data Protection Officer (DPO)

For matters relating to privacy, data protection, or the exercise of your privacy rights, you may contact our designated Data Protection Officer (DPO).

Data Protection Officer
AzariPay Technologies Ltd

Email: privacy@azaripay.co

3. Customer Support

For general enquiries relating to your AzariPay account or services, please contact our Customer Support team.

Customer Support Email: support@azaripay.co

Customer Support Telephone: +234 201 330 1358

4. Corporate Office

AzariPay Technologies Ltd

Registered Office: (Abuja, Nigeria)

5. Website

Official Website:

www.azaripay.co

6. Exercising Your Privacy Rights

You may contact us to:

• Access your personal information;
• Request correction or update of your information;
• Request deletion where applicable;
• Withdraw consent where processing is based on consent;
• Object to certain processing activities;
• Request restriction of processing;
• Request data portability where applicable;
• Ask questions regarding our privacy practices;
• Report suspected privacy or security incidents; or
• Submit complaints relating to the processing of your personal information.

To protect your privacy and the security of your account, AzariPay may require reasonable verification of your identity before processing your request.

7. Complaints

If you believe that AzariPay has not handled your personal information in accordance with applicable data protection laws, we encourage you to contact us first so that we have an opportunity to investigate and resolve your concerns.

If you remain dissatisfied, you may have the right to lodge a complaint with the relevant data protection authority or supervisory authority in your jurisdiction, subject to applicable law.

8. Response Time

AzariPay will acknowledge and respond to privacy-related requests and complaints within the timeframes required by applicable law. Where additional time is reasonably necessary due to the complexity or volume of requests, we will notify you accordingly where required.

9. Business Hours

Customer Support and privacy enquiries are generally handled during AzariPay’s published business hours. However, security incidents, fraud reports, and urgent account protection matters may be reported at any time through the designated emergency support channels where available.

10. Updates to Contact Information

AzariPay may update the contact details provided in this section from time to time. The most current contact information will always be available through our official website and mobile application.

Governing Law

1. Applicable Law

This Privacy Policy shall be governed by and construed in accordance with the laws of the Federal Republic of Nigeria, including the Nigeria Data Protection Act, 2023 (NDPA), applicable regulations issued by the Nigeria Data Protection Commission (NDPC), and all other applicable laws, regulations, directives, and regulatory guidelines governing the collection, processing, storage, transfer, disclosure, and protection of personal information.

Where AzariPay operates in or provides services to customers in other jurisdictions, this Privacy Policy shall also be interpreted and applied in a manner consistent with any mandatory data protection, consumer protection, financial services, payment services, anti-money laundering, or other applicable laws of those jurisdictions to the extent required.

2. Regulatory Compliance

AzariPay is committed to maintaining compliance with all applicable laws and regulatory requirements governing its operations. Nothing in this Privacy Policy shall be interpreted as limiting or excluding any obligation imposed upon AzariPay by law or any lawful request or direction issued by a competent regulatory, supervisory, judicial, or law enforcement authority.

3. International Operations

As AzariPay expands its products and services internationally, certain aspects of this Privacy Policy may be supplemented by additional privacy notices or jurisdiction-specific disclosures required by local laws.

Where a mandatory provision of applicable law in a particular jurisdiction conflicts with this Privacy Policy, the mandatory legal requirement shall prevail to the extent of that conflict, while the remaining provisions of this Privacy Policy shall continue in full force and effect.

4. Dispute Resolution

Any dispute, claim, complaint, or controversy arising from or relating to this Privacy Policy or the processing of personal information by AzariPay shall, where appropriate and to the extent permitted by applicable law, first be addressed through good-faith discussions between the parties.

Where a dispute cannot be resolved amicably, it shall be resolved in accordance with the dispute resolution provisions contained in the applicable AzariPay Terms and Conditions or any other agreement governing the relationship between AzariPay and the customer.

Nothing in this section prevents a customer from exercising any statutory right to submit a complaint to a competent data protection authority or financial services regulator where such right is provided by applicable law.

5. Jurisdiction

Subject to any mandatory rights available under applicable law, the courts of the Federal Republic of Nigeria shall have jurisdiction over matters arising from or relating to this Privacy Policy, unless another forum is required by law or agreed in writing between the parties.

6. Severability

If any provision of this Privacy Policy is determined by a court or competent authority to be invalid, unlawful, or unenforceable, that provision shall be deemed severed to the minimum extent necessary, and the remaining provisions shall continue in full force and effect.

7. Entire Privacy Policy

This Privacy Policy constitutes the complete statement of AzariPay’s privacy practices relating to the collection, use, disclosure, storage, transfer, retention, and protection of personal information. It should be read together with AzariPay’s Terms and Conditions, Cookie Policy (where applicable), and any product-specific or jurisdiction-specific privacy notices issued by AzariPay.

8. Survival

Any provisions of this Privacy Policy which, by their nature, are intended to survive the termination, suspension, or closure of a customer’s account—including provisions relating to data retention, regulatory compliance, confidentiality, dispute resolution, limitation of liability, and governing law—shall remain in effect for as long as necessary to fulfil their intended purpose or comply with applicable legal obligations.

9. Acceptance

By accessing or using AzariPay’s website, mobile application, digital wallet, business services, cross-border payment services, Azari Select, or any other products or services, you acknowledge that you have read, understood, and accepted this Privacy Policy and agree that it shall be governed and interpreted in accordance with the laws and principles set out in this section, subject always to any mandatory rights or protections available under applicable law.

Limitation of Liability

1. General Limitation

AzariPay Technologies Ltd (“AzariPay“, “we“, “our“, or “us“) is committed to implementing appropriate technical, organisational, and administrative measures to protect your personal information. However, no method of electronic transmission, internet communication, cloud storage, or information security system can be guaranteed to be completely secure or free from interruption, error, or unauthorised access.

Accordingly, while AzariPay exercises reasonable care in protecting your personal information, we cannot guarantee absolute security.

2. No Guarantee of Uninterrupted Services

AzariPay does not warrant or guarantee that:

• Our website, mobile application, APIs, or other digital platforms will operate without interruption or error;
• Data transmissions will always be secure;
• Security systems will prevent every cyberattack or security incident;
• Third-party services or infrastructure will remain continuously available;
• Information stored electronically will never be lost, corrupted, or altered; or
• Services will always be available in every jurisdiction.

3. Third-Party Services

AzariPay relies on independent third parties, including financial institutions, payment networks, cloud infrastructure providers, telecommunications operators, identity verification providers, merchants, concierge partners, technology vendors, and regulatory infrastructure.

To the fullest extent permitted by applicable law, AzariPay shall not be responsible for losses, delays, service interruptions, security incidents, unauthorised disclosures, or damages arising directly from the acts, omissions, failures, negligence, or systems of independent third parties that are outside AzariPay’s reasonable control.

4. Customer Responsibilities

Customers are responsible for maintaining the confidentiality and security of their:

• Passwords;
• One-Time Passwords (OTPs);
• Personal Identification Numbers (PINs);
• Authentication devices;
• Mobile devices;
• Email accounts;
• Security credentials; and
• Other account access information.

AzariPay shall not be liable for losses resulting from:

• Disclosure of security credentials by the customer;
• Weak passwords or inadequate device security;
• Failure to implement available security features;
• Unauthorised access caused by customer negligence;
• Fraud arising from phishing, social engineering, SIM swap fraud, malware, or other attacks where the customer failed to exercise reasonable care; or
• Failure to promptly notify AzariPay of suspected unauthorised activity.

5. Force Majeure

AzariPay shall not be liable for any delay, interruption, failure, or inability to perform its obligations resulting from events beyond its reasonable control, including but not limited to:

• Natural disasters;
• Floods;
• Fires;
• Epidemics or pandemics;
• Acts of war or terrorism;
• Civil unrest;
• Government actions or regulatory restrictions;
• Power failures;
• Internet or telecommunications outages;
• Cyberattacks affecting critical infrastructure;
• Labour disputes;
• Banking or payment network failures; or
• Other force majeure events.

6. Indirect and Consequential Losses

To the fullest extent permitted by applicable law, AzariPay shall not be liable for any indirect, incidental, special, exemplary, punitive, or consequential losses or damages arising from or relating to this Privacy Policy or the processing of personal information, including but not limited to:

• Loss of profits;
• Loss of revenue;
• Loss of business opportunities;
• Loss of goodwill;
• Loss of anticipated savings;
• Loss of data not caused by AzariPay’s wilful misconduct or gross negligence;
• Business interruption; or
• Reputational damage.

7. Regulatory and Legal Compliance

AzariPay shall not be liable for any action taken in good faith to comply with applicable laws, regulations, court orders, regulatory directives, sanctions programmes, anti-money laundering obligations, fraud prevention measures, or lawful requests from competent authorities.

Such actions may include delaying, restricting, monitoring, reporting, suspending, or refusing transactions or services where legally required or reasonably necessary.

8. Data Accuracy

AzariPay relies on the accuracy of information provided by customers and authorised third parties.

We shall not be responsible for losses arising from inaccurate, incomplete, outdated, misleading, or fraudulent information supplied by customers or third parties upon which AzariPay reasonably relied.

9. Security Incidents

In the event of a security incident, AzariPay will take reasonable steps to investigate, contain, mitigate, and respond in accordance with applicable law and our internal incident response procedures.

Except where caused by our negligence, wilful misconduct, or breach of applicable law, AzariPay shall not be liable for losses arising from criminal acts, cyberattacks, sophisticated hacking, malware, ransomware, or other malicious activities carried out by third parties that could not reasonably have been prevented despite the implementation of appropriate security measures.

10. Limitation Permitted by Law

Nothing in this Privacy Policy shall exclude or limit any liability that cannot lawfully be excluded or limited under applicable law, including liability arising from:

• Fraud or fraudulent misrepresentation by AzariPay;
• Wilful misconduct;
• Gross negligence where exclusion is prohibited by law; or
• Any other liability that applicable law does not permit to be excluded or restricted.

11. Customer Acknowledgement

By using AzariPay’s products and services, you acknowledge that:

• Electronic communications and online financial services involve inherent risks;
• Absolute security cannot be guaranteed;
• Third-party systems and infrastructure form part of the delivery of our services;
• You are responsible for safeguarding your account credentials and devices; and
• The limitations of liability set out in this Privacy Policy are reasonable, proportionate, and intended to allocate risk fairly between you and AzariPay, subject always to your mandatory legal rights.

12. Survival

This Limitation of Liability section shall survive the suspension, closure, or termination of your AzariPay account and shall continue to apply to the fullest extent permitted by applicable law with respect to matters arising before or after such suspension, closure, or termination.

Regulatory Disclosures

1. Commitment to Regulatory Compliance

AzariPay Technologies Ltd (“AzariPay“, “we“, “our“, or “us“) is committed to operating in compliance with all applicable laws, regulations, regulatory directives, industry standards, and licensing requirements governing our products and services.

As a financial technology company, we may be required to collect, process, retain, disclose, and transfer personal information in order to comply with legal and regulatory obligations imposed by competent authorities in the jurisdictions where we operate.

2. Regulatory Authorities

Depending on the products and services provided and the jurisdictions in which we operate, AzariPay may be subject to oversight by one or more regulatory, supervisory, or enforcement authorities, including but not limited to:

• Financial services regulators;
• Central banks;
• Data protection authorities;
• Financial Intelligence Units (FIUs);
• Anti-money laundering and counter-terrorist financing authorities;
• Tax authorities;
• Consumer protection agencies;
• Law enforcement agencies;
• Judicial authorities;
• Payment system operators; and
• Other competent governmental or regulatory bodies.

3. Mandatory Collection and Processing

Certain personal information is collected because AzariPay is legally required to do so.

Such information may include:

• Identity verification information;
• Know Your Customer (KYC) information;
• Know Your Business (KYB) documentation;
• Ultimate Beneficial Owner (UBO) information;
• Contact information;
• Transaction records;
• Source of funds and source of wealth information where applicable;
• Tax-related information;
• Device and security information;
• Fraud monitoring information; and
• Other information required by applicable law.

Where the provision of certain information is mandatory, failure to provide it may prevent AzariPay from opening an account, processing transactions, or continuing to provide particular services.

4. Regulatory Reporting

AzariPay may disclose personal information to competent authorities where required or authorised by applicable law.

Such disclosures may include reports relating to:

• Suspicious transactions;
• Fraud investigations;
• Anti-money laundering (AML) compliance;
• Counter-terrorist financing (CTF) compliance;
• Counter-proliferation financing (CPF) compliance;
• Sanctions compliance;
• Tax reporting obligations;
• Regulatory examinations;
• Financial audits;
• Court orders;
• Law enforcement investigations; and
• Other mandatory reporting obligations.

Such disclosures may occur without prior notice where permitted or required by law.

5. Screening and Monitoring

To comply with applicable laws and protect the integrity of the financial system, AzariPay may conduct ongoing:

• Identity verification;
• Customer due diligence;
• Enhanced due diligence;
• Transaction monitoring;
• Sanctions screening;
• Politically Exposed Person (PEP) screening;
• Adverse media screening where appropriate;
• Fraud detection;
• Risk assessments;
• Account monitoring; and
• Other compliance-related reviews.

These activities may be conducted using both automated technologies and appropriately authorised personnel.

6. Record Retention

AzariPay retains personal information and transaction records for the periods required by applicable financial services, anti-money laundering, taxation, accounting, audit, payment services, and data protection laws.

Information may continue to be retained after an account has been closed where required by law or necessary to establish, exercise, or defend legal claims.

7. International Regulatory Cooperation

Where AzariPay operates internationally or facilitates cross-border transactions, personal information may be disclosed to foreign regulators, correspondent financial institutions, payment networks, or other competent authorities where required by applicable law, international agreements, or lawful regulatory requests.

Such transfers will be carried out in accordance with applicable data protection laws and the International Data Transfers section of this Privacy Policy.

8. Customer Cooperation

Customers may be required to provide additional documentation or information in order to satisfy regulatory obligations.

This may include updated:

• Identity documents;
• Business registration records;
• Proof of address;
• Source of funds documentation;
• Source of wealth information;
• Tax information;
• Beneficial ownership details;
• Transaction explanations; or
• Other information reasonably required for compliance purposes.

Failure to cooperate with reasonable compliance requests may result in delayed onboarding, transaction delays, restrictions, suspension, or termination of services where permitted by applicable law.

9. Regulatory Changes

Financial services and data protection laws continue to evolve.

AzariPay may update its compliance procedures, onboarding requirements, customer verification processes, transaction monitoring practices, record retention periods, and this Privacy Policy as necessary to comply with new or amended legal and regulatory requirements.

10. No Waiver of Legal Obligations

Nothing in this Privacy Policy limits AzariPay’s ability or obligation to comply with applicable laws, regulations, regulatory directives, judicial orders, law enforcement requests, sanctions programmes, or other lawful requirements imposed by competent authorities.

Where a legal obligation conflicts with another provision of this Privacy Policy, the applicable legal obligation shall prevail to the extent of the conflict.

11. Customer Acknowledgement

By using AzariPay’s products and services, you acknowledge and agree that AzariPay may collect, process, retain, monitor, verify, disclose, and transfer your personal information where necessary to:

• Comply with applicable laws and regulatory obligations;
• Prevent fraud, money laundering, terrorist financing, sanctions evasion, and other financial crimes;
• Protect the integrity of the financial system;
• Cooperate with competent regulatory, supervisory, judicial, and law enforcement authorities; and
• Maintain the security, reliability, and lawful operation of AzariPay’s products and services.

Such processing will always be carried out in accordance with applicable law and the safeguards described throughout this Privacy Policy.