PRIVACY POLICY

Effective Date: 01/01/2024 | Last Updated: 01/05/2025

At CanPay, your privacy is important to us. This Privacy Policy explains how we collect, use, store, and share your personal information when you use our Buy Now, Pay Later services in Ghana.

1. Who We Are

CanPay ("we", "our", or "us") is a financial technology company based in Ghana that offers instalment payment solutions. We are committed to protecting your privacy in accordance with the Data Protection Act, 2012 (Act 843) of Ghana.

2. Information We Collect

We collect the following types of information:

  • Personal Information
    • Full name
    • Date of birth
    • Ghana Card or other government-issued ID
    • Contact information (email, phone number)
    • Employment details
    • Residential address
  • Financial Information
    • Mobile money account details
    • Bank account information
    • Payment and transaction history
    • Credit reports or scoring data (with your consent)
  • Device and Usage Information
    • IP address
    • Device identifiers
    • Browser type and version
    • Usage logs and access times
  • Merchant and Transaction Data
    • Details of purchases made through CanPay
    • Interactions with partner merchants

3. How We Use Your Information

  • We use your information to:
    • Create and manage your CanPay account
    • Assess your creditworthiness and eligibility for BNPL services
    • Process and manage payments
    • Communicate with you about your transactions and account
    • Prevent fraud and unauthorized access
    • Comply with legal and regulatory obligations
    • Improve our services and customer experience

4. Legal Basis for Processing

  • We rely on the following legal grounds:
    • Consent: When you agree to share your data during sign-up.
    • Contract: To fulfil our agreement to provide BNPL services.
    • Legal Obligation: To comply with financial and regulatory laws.
    • Legitimate Interest: For fraud prevention, service improvement, and business analytics.

CanPay reserves the right to debit your account or mobile wallet for any outstanding amounts.

5. Sharing of Your Information

  • We may share your information with:
    • Partner merchants to facilitate your purchases
    • Credit bureaus for credit assessments and reporting
    • Payment processors for transaction handling
    • Service providers that help us with technology, identity verification, and analytics
    • Regulatory authorities, if legally required

We do not sell your personal data to third parties.

6. Data Retention

  • We retain your data only for as long as necessary to:
    • Provide our services
    • Meet legal and tax obligations
    • Resolve disputes
    • Enforce agreements

Typically, this is up to 6 years after account closure unless legally required otherwise.

7. Your Rights

  • Under Ghanaian data protection law, you have the right to:
    • Access the personal data we hold about you
    • Request correction or deletion of your data
    • Object to or restrict certain processing
    • Withdraw your consent (where processing is based on consent)
    • Lodge a complaint with the Data Protection Commission of Ghana

8. Data Security

  • We use administrative, technical, and physical safeguards to protect your data, including:
    • Encryption
    • Access controls
    • Secure servers
    • Regular security audits

9. Children's Privacy

CanPay’s services are not intended for persons under 18. We do not knowingly collect data from minors.

10. International Data Transfers

As a Ghana-based business, your data is primarily stored and processed within Ghana. If any international transfers are necessary (e.g., via third-party service providers), we ensure appropriate data protection safeguards are in place.

11. Changes to This Policy

We may update this Privacy Policy from time to time. You will be notified of significant changes. Continued use of CanPay after updates indicates your acceptance of the revised policy.