Privacy Policy

Effective Date: 2026-03-01

CushPay ("we," "us," "our," or "Company") is committed to protecting your privacy. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you use our mobile application and services.

1. Information We Collect

We collect information you provide directly, including phone number and PIN, personal details (name, email, date of birth, address), payment and transaction information, network and device information, crash diagnostics, location-related data for security checks, login activity data, KYC documentation, biometric data (if enabled), and communications you send us.

2. How We Use Your Information

We use your information to create and manage your account, process transactions, comply with KYC/AML regulations, verify your identity and prevent fraud, detect suspicious access, diagnose crashes, improve our services, send transaction updates, and enforce our terms.

3. Information Sharing

We do not sell, trade, or rent your personal information. We may share it with payment processors, security/infrastructure providers, regulators and law enforcement when required, and other parties with your explicit consent.

4. Data Security

We implement industry-standard security measures including encryption, secure transmission protocols, and access controls. No method of transmission over the internet is completely secure.

5. Biometric Data

Face ID or fingerprint data is stored locally on your device and never transmitted to our servers. You can disable this feature at any time.

6. KYC Compliance

To comply with AML/CTF regulations, we require KYC information such as identification, address verification, and source of funds documentation where applicable.

7. Transaction History & Saved Recipients

We maintain transaction and recipient records to provide history, enable quick transfers, detect fraud, and meet regulatory requirements.

8. Referral Program

Referral program participation involves collecting information about referred users solely to manage and administer rewards.

9. Your Rights

Depending on your jurisdiction, you may access, correct, or request deletion of your data, opt out of promotional communications, or withdraw consent for biometric features. Contact us to exercise these rights.

10. Retention Period

We retain information as long as necessary for services and legal compliance. Transaction records are retained for at least 5 years. Security logs may be retained to detect and prevent fraud.

11. Children's Privacy

CushPay is not intended for users under 18. We do not knowingly collect information from children.

12. Device Permissions

Camera: Used solely to scan QR codes for payments.

Location: Used to detect unusual login activity and prevent fraud. Never used for advertising.

13. Policy Updates

We may update this Privacy Policy periodically. Changes will be reflected by updating the Effective Date above.

14. Contact Us

Email: privacy@cushpay.app