WazzoPay Privacy & Customer Care Policy

This Privacy Statement covers all aspects of how WazzoPay handles your personal data, including:

Children & Vulnerable Persons — how we treat data belonging to minors and persons with disabilities.

Customer care practices, grievance redressal, and communication standards.

This policy applies to all WazzoPay products, services, platforms, and interactions.

• Data Collection — what information we gather from you and how we obtain it.
• Data Usage — how we use your data to deliver financial and insurance services.
• Data Sharing — when and why we share your data with third parties.
• Data Protection — how we safeguard your information.
• User Rights — your rights under Sierra Leonean law.
• Cookies & Tracking — how we use cookies and similar technologies.

WazzoPay operates under the legal and regulatory framework of Sierra Leone. Our data practices comply with:

• The Sierra Leone Data Protection Act (or applicable data privacy regulations)

The Bank of Sierra Leone (BSL) Guidelines for financial institutions, mobile money operators, and digital financial services

• The Insurance Act of Sierra Leone governing underwriting, claims, and insurance data
• AntiMoney Laundering and Combating of Financing of Terrorism (AML/CFT) Regulations

Any dispute arising from this Privacy Statement shall fall under the exclusive jurisdiction of the courts of Sierra Leone.

• The National Telecommunication Commission (NATCOM) Regulations
• The Cybercrime Act of Sierra Leone
• Consumer Protection and Fair Competition Laws

WazzoPay collects personal data necessary to provide secure, compliant, and efficient financial and insurance services. This includes:

• Emergency contact details (if required for insurance or loan services)
• Facial recognition or fingerprint authentication (if enabled by the user)

• 1. Identity Information
• Full name
• Date of birth
• Gender
• National Identification Number (NIN)
• Passport, voter ID, driver’s license, or other KYC documents
• Photographs or scanned copies of identification documents
• Signature (digital or physical)
• 2. Contact Information
• Mobile phone number
• Email address
• Residential or business address
• 3. Financial Information
• Bank account details
• Mobile money wallet details
• Transaction history (payments, transfers, deposits, withdrawals)
• Loan applications, approvals, repayment history
• Insurance policy details, claims, premium payments
• Credit bureau information (where applicable)
• 4. Device & Technical Data
• IP address
• Device type, model, and operating system
• Mobile network information
• App usage analytics
• Browser type and version
• Crash logs and diagnostic data
• 5. Location Data
• GPS location (if enabled)
• Networkbased location
• Location patterns for fraud detection and service optimization
• 6. Biometric Data
• Voice verification (if used for customer care authentication)
• 7. Behavioural & Risk Data
• Loan behaviour and repayment patterns
• Insurance risk profiles
• Spending habits and transaction preferences
• Fraud risk indicators
• 8. Communication Data
• Customer care interactions
• Emails, chat messages, and call logs
• Feedback, complaints, and survey responses

• WazzoPay processes your data for the following purposes:
• 1. Service Delivery
• Creating and managing your WazzoPay account
• Facilitating payments, transfers, and wallet services
• Processing insurance applications, claims, and renewals
• Assessing loan eligibility and managing loan lifecycle
• Enabling utility bill payments and merchant transactions
• 2. Regulatory Compliance
• Conducting KYC verification
• Performing AML/CFT checks
• Reporting to regulators (BSL, FIU, NATCOM)
• Maintaining mandatory financial and insurance records
• 3. Fraud Prevention & Security
• Monitoring suspicious activities
• Detecting unauthorized access
• Verifying identity using biometric or device data
• Preventing money laundering, fraud, and cybercrime
• 4. Personalization & User Experience
• Tailoring product recommendations
• Improving app performance and usability
• Providing relevant offers and promotions
• Enhancing customer support interactions
• 5. Communication
• Sending transaction alerts
• Providing service updates
• Responding to customer care inquiries
• Delivering regulatory or policy notifications
• 6. Internal Operations
• Data analytics and business intelligence
• Product development and testing
• System maintenance and troubleshooting

WazzoPay does not knowingly collect data from minors unless permitted by law and supported by a parent or legal guardian.

If we discover unauthorized use by a minor, we will immediately delete the data.

WazzoPay ensures accessible communication channels.

Consent processes are simplified and clearly explained.

Customer care agents are trained to provide enhanced support.

Alternative verification methods may be used when necessary.

• Children (Under 18 Years)
• Persons with Disabilities

Yes. WazzoPay uses cookies and similar technologies to improve user experience and security.

You may disable cookies in your browser or device settings, but some features may not function properly.

• Types of Cookies Used
• Session Cookies — maintain secure login sessions.
• Preference Cookies — remember user settings and preferences.
• Analytics Cookies — help us understand usage patterns and improve performance.
• Security Cookies — detect suspicious behaviour and protect your account.
• Other Tracking Technologies
• Web beacons
• Pixel tags
• Device fingerprinting
• SDKs integrated into the mobile app

WazzoPay may share your data with trusted third parties only when necessary and lawful.

WazzoPay does not sell your personal data.

• 1. Financial Partners
• Banks
• Mobile money operators
• Payment processors
• Credit bureaus
• 2. Insurance Partners
• Underwriters
• Claims processors
• Actuarial service providers
• 3. Regulators
• Bank of Sierra Leone
• Financial Intelligence Unit (FIU)
• NATCOM
• Insurance regulatory bodies
• 4. Service Providers
• Cloud hosting providers
• SMS and email gateway providers
• Data analytics companies
• Customer care platforms
• 5. Affiliates & Subsidiaries
• Entities owned or controlled by WazzoPay
• Joint venture partners
• 6. Law Enforcement
• When required by court order, warrant, or legal obligation

Yes, but only when necessary for service delivery or compliance.

All transfers comply with data protection standards equivalent to Sierra Leone’s regulatory requirements, and contractual safeguards are applied.

• International transfers may occur for:
• Cloud hosting
• Fraud detection
• Payment processing
• Insurance underwriting
• Data analytics

• WazzoPay uses industrygrade security measures to protect your data:
• Technical Safeguards
• Endtoend encryption
• Multifactor authentication (MFA)
• Secure server infrastructure
• Firewalls and intrusion detection systems
• Regular vulnerability assessments
• Data anonymization and minimization
• Organizational Safeguards
• Strict access controls
• Employee confidentiality agreements
• Regular cybersecurity training
• Incident response protocols
• Thirdparty security audits
• UserLevel Safeguards
• Secure login procedures
• Alerts for suspicious activity
• Tools to manage privacy settings

When data is no longer required, it is securely deleted, anonymized, or archived according to regulatory standards.

• We retain your data only as long as necessary for:
• Regulatory compliance
• Fraud prevention
• Service delivery
• Insurance and loan recordkeeping
• Legal obligations
• Dispute resolution

We will notify you through inapp alerts, email, or website announcements.

The updated version will include a “Last Updated” date.

Continued use of WazzoPay after changes means you accept the updated policy.

• If we update this Privacy Statement:

For questions, concerns, or grievances regarding your personal data, contact our Privacy & Grievance Officer:

• Email: privacy.grievanceofficer@wazzopay.com Office: WazzoPay Headquarters, Freetown, Sierra Leone

You may contact us on any aspect of this Privacy Statement or for any grievance(s) with respect to your Personal Data.