havenpay
Privacy policy
HavenPay (“we”, “our”, “us”) is committed to protecting your privacy and ensuring that your personal information is handled securely, lawfully, and transparently. This Privacy Policy explains how we collect, use, store, and protect your data when you use the HavenPay mobile wallet and related services.
01
Information We Collect
We collect the following categories of information:
1.1 Identity Information
To meet regulatory and compliance standards, we may collect and verify: UNHCR ID or other humanitarian-issued identification, Passport, refugee ID, or government-issued documents (when applicable), Biometric verification (such as facial recognition or liveness checks), Date of birth and gender, Refugee registration numbers, Proof of residence or address (mobile, digital, or geo-tag based)
1.2 Contact Information
Phone number, Email address, Device information, Preferred language
1.3 Financial & Transaction Information
Wallet balanceDeposits, withdrawals, and transfers M-Pesa or bank-linked transaction history. Payment recipients and senders. Aid disbursement history from NGOs (when relevant)
1.4 Behavioral & Usage Data
App interactions, Login activity, Device identifiers, Security logs, Creditworthiness signals (e.g., repayment behavior, transaction patterns)
1.5 Location Information
Approximate location from device or transactions (only when needed for fraud detection, compliance, or digital address verification)
1.1 Identity Information
To meet regulatory and compliance standards, we may collect and verify: UNHCR ID or other humanitarian-issued identification, Passport, refugee ID, or government-issued documents (when applicable), Biometric verification (such as facial recognition or liveness checks), Date of birth and gender, Refugee registration numbers, Proof of residence or address (mobile, digital, or geo-tag based)
1.2 Contact Information
Phone number, Email address, Device information, Preferred language
1.3 Financial & Transaction Information
Wallet balanceDeposits, withdrawals, and transfers M-Pesa or bank-linked transaction history. Payment recipients and senders. Aid disbursement history from NGOs (when relevant)
1.4 Behavioral & Usage Data
App interactions, Login activity, Device identifiers, Security logs, Creditworthiness signals (e.g., repayment behavior, transaction patterns)
1.5 Location Information
Approximate location from device or transactions (only when needed for fraud detection, compliance, or digital address verification)
02
How We Use Your Information
We process your data to provide safe, legal, and compliant financial services.
We use your information to:
- Verify your identity and meet KYC/AML/CTF requirements
- Create and manage your HavenPay account
- Facilitate savings, transfers, payments, and withdrawals
- Detect and prevent fraud or unauthorized activity
- Provide customer support and resolve issues
- Conduct risk scoring and build credit profilesImprove app performance and user experience
- Comply with regulatory obligations in Kenya and other jurisdictions
We do not sell your personal information.
We use your information to:
- Verify your identity and meet KYC/AML/CTF requirements
- Create and manage your HavenPay account
- Facilitate savings, transfers, payments, and withdrawals
- Detect and prevent fraud or unauthorized activity
- Provide customer support and resolve issues
- Conduct risk scoring and build credit profilesImprove app performance and user experience
- Comply with regulatory obligations in Kenya and other jurisdictions
We do not sell your personal information.
03
How We Share Your Information
We only share your data with trusted partners when required to provide services or meet legal obligations.
We may share information with:
- Financial institutions such as Choice Bank (for regulated wallets and accounts)
- Mobile money providers (e.g., M-Pesa/Safaricom) to process transactionsUNHCR, for identity verification where applicable
- NGOs or aid partners, when processing aid distributions
- Regulators and law enforcement, when legally required
- Technology and security vendors, who support fraud detection, cloud hosting, and analytics
All third parties are bound by strict confidentiality and data protection agreements.
We may share information with:
- Financial institutions such as Choice Bank (for regulated wallets and accounts)
- Mobile money providers (e.g., M-Pesa/Safaricom) to process transactionsUNHCR, for identity verification where applicable
- NGOs or aid partners, when processing aid distributions
- Regulators and law enforcement, when legally required
- Technology and security vendors, who support fraud detection, cloud hosting, and analytics
All third parties are bound by strict confidentiality and data protection agreements.
04
Legal Basis for Processing
We process your data based on:
- Consent (e.g., scanning a UNHCR ID)
- Contractual necessity (to provide HavenPay wallet services)
- Legal obligation (KYC/AML regulations)
- Legitimate interest (fraud prevention and service improvement)
- Consent (e.g., scanning a UNHCR ID)
- Contractual necessity (to provide HavenPay wallet services)
- Legal obligation (KYC/AML regulations)
- Legitimate interest (fraud prevention and service improvement)
05
How We Protect Your Information
We use industry-standard physical, technical, and administrative measures:
- Encryption of data in transit and at rest
- Biometric authentication for sensitive actions
- Continuous transaction monitoring
- Fraud detection tools and automated alerts
- Strict access controls and security audits
- Secure cloud infrastructure
If a data breach occurs, we will notify affected users and regulators as required by law.
- Encryption of data in transit and at rest
- Biometric authentication for sensitive actions
- Continuous transaction monitoring
- Fraud detection tools and automated alerts
- Strict access controls and security audits
- Secure cloud infrastructure
If a data breach occurs, we will notify affected users and regulators as required by law.
06
How Long We Keep Your Data
We retain data only for as long as necessary to:
- Provide services
- Meet regulatory and financial compliance requirements
- Resolve disputes
- Maintain accurate records for law enforcement and audit obligations
When data is no longer required, it is securely deleted or anonymized.
- Provide services
- Meet regulatory and financial compliance requirements
- Resolve disputes
- Maintain accurate records for law enforcement and audit obligations
When data is no longer required, it is securely deleted or anonymized.
07
Your Rights
Depending on your country of residence, you may have the right to:
- Access your personal dataRequest correction or updates
- Request deletion (subject to regulatory limits)
- Withdraw consent (where applicable)
- Request a portable copy of your data
- Object to certain types of processing
To exercise your rights, contact us at: privacy@havenpay.co
- Access your personal dataRequest correction or updates
- Request deletion (subject to regulatory limits)
- Withdraw consent (where applicable)
- Request a portable copy of your data
- Object to certain types of processing
To exercise your rights, contact us at: privacy@havenpay.co
08
International Transfers
If your data is transferred outside your country, we ensure equivalent levels of protection through:
- Data protection agreements
- Secure transfer mechanisms
- Regulatory compliance frameworks
- Data protection agreements
- Secure transfer mechanisms
- Regulatory compliance frameworks
09
Children’s Data
HavenPay does not knowingly allow users under 18 to create accounts without proper guardian or regulatory authorization.
10
Updates to Policy
We may update this Privacy Policy as our services evolve or to meet legal requirements. Updated versions will be posted on our website with a revised “Last Updated” date.
11
Contact Us
For any privacy-related questions or concerns:
HavenPay Ltd
Email: privacy@havenpay.co
Website: www.havenpay.co
HavenPay Ltd
Email: privacy@havenpay.co
Website: www.havenpay.co
