WazzoPay Privacy Policy

We collect and process information only where we have a lawful basis to do so.

We process personal information fairly and in ways that customers would reasonably expect.

We clearly explain what information we collect and how it is used.

Information is collected only for specified, legitimate purposes.

We collect only the information necessary to provide our services and comply with legal obligations.

We take reasonable steps to ensure personal information is accurate and kept up to date.

We implement appropriate technical and organisational measures to safeguard personal information from unauthorised access, loss, misuse, alteration, or disclosure.

WazzoPay is accountable for complying with this Privacy Policy and applicable data protection laws.

Where appropriate, customers are provided with choices regarding how their personal information is collected, used, and shared, subject to legal and regulatory requirements.

To comply with applicable laws, including anti-money laundering (AML), counter-terrorism financing (CFT), sanctions screening, fraud prevention, and customer due diligence obligations, WazzoPay may collect information necessary to verify your identity.

This may include:

• Full legal name
• Date of birth
• Gender
• Nationality
• National Identification Number (NIN)
• Passport details
• Driver's Licence details
• Voter Identification Card details
• Tax Identification Number (where applicable)
• Residential status
• Occupation
• Employer information
• Marital status (where required by law or for specific financial products)
• Photographs of identity documents
• Selfie photographs used for identity verification
• Live facial verification (where applicable)
• Signature (electronic or handwritten)

Other identity verification information required by applicable laws or regulators.

We may also verify your identity against trusted third-party identity databases and government records where legally permitted.

To communicate with you and provide our services, we may collect:

• Residential address
• Postal address
• Email address
• Mobile telephone number
• Alternative contact numbers
• Emergency contact details (where applicable)
• Preferred language

Preferred communication channels.

We use this information to send security notifications, account alerts, transaction confirmations, service updates, promotional communications (where permitted), and customer support responses.

When creating a WazzoPay account, we may collect:

• Username
• Password (stored securely using industry-standard hashing techniques)
• Security questions and answers
• Multi-factor authentication preferences
• Device registration information
• Account preferences
• Notification settings
• Profile information
• Referral codes

Promotional campaign participation.

We use this information to create, authenticate, and manage your account securely.

To facilitate financial services, WazzoPay may collect information relating to your financial profile, including:

• Bank account details
• Account numbers
• Bank Verification Number (where applicable)
• Mobile money account details
• Debit and credit card information (processed securely through authorised payment providers)
• Wallet balances
• Source of funds
• Income information
• Salary information
• Employment income
• Business income
• Transaction limits
• Payment preferences
• Funding methods
• Withdrawal preferences

Financial goals (where voluntarily provided).

Sensitive payment credentials are processed in accordance with applicable payment security standards and are not stored unless required for lawful operational purposes.

Whenever you use WazzoPay, we collect transaction information necessary to process and maintain accurate records of your activities.

This may include:

• Payment amounts
• Transaction references
• Transaction dates and times
• Currency
• Sender information
• Recipient information
• Merchant information
• QR payment details
• Utility bill payment information
• Airtime and data purchases
• School fee payments
• Government service payments
• Insurance premium payments
• Loan repayments
• Refunds
• Chargebacks
• Transaction status
• Payment authorisations

Receipts and invoices.

This information enables us to process transactions, detect fraud, resolve disputes, maintain audit trails, comply with legal obligations, and improve our services.

Where you purchase or enquire about insurance products through WazzoPay, we may collect information relevant to underwriting, policy administration, claims processing, and regulatory compliance.

Depending on the type of insurance, this may include:

• Insurance preferences
• Risk profile information
• Household information
• Property information
• Vehicle information
• Agricultural information
• Livestock information
• Business information
• Beneficiary details
• Existing insurance policies
• Claims history
• Supporting documentation
• Photographs
• Incident reports
• Medical declarations (where applicable)
• Health information necessary to administer specific insurance products

Information provided during claims investigations.

Certain insurance products may require the collection of sensitive personal information. Such information will only be processed where necessary, with appropriate safeguards and in accordance with applicable law.

Where you apply for loans or other credit-related products through WazzoPay or our financial partners, we may collect information including:

• Employment information
• Employer details
• Income and expenditure
• Business turnover
• Cash flow information
• Inventory information
• Existing debts
• Loan repayment history
• Banking history
• Credit history
• Alternative credit indicators
• Savings behaviour
• Utility payment history
• Financial commitments

Supporting documents submitted with loan applications.

This information assists in assessing affordability, eligibility, fraud prevention, responsible lending, and regulatory compliance.

Where businesses register with WazzoPay, we may collect:

• Registered business name
• Business registration number
• Tax identification number
• Business licences
• Registered address
• Trading address
• Directors' information
• Beneficial ownership information
• Bank account details
• Merchant category
• Business turnover
• Product and service information
• Settlement preferences
• Website details

Social media accounts (where voluntarily provided).

This information supports merchant onboarding, payment processing, fraud prevention, and regulatory compliance.

When you contact WazzoPay through any communication channel, we may collect:

• Emails
• Live chat messages
• Telephone recordings
• Customer support tickets
• Complaints
• Feedback
• Surveys
• Social media interactions

Documents submitted during investigations.

These communications may be recorded, monitored, and retained to improve service quality, resolve disputes, train employees, enhance customer experience, and comply with legal obligations.

You may voluntarily provide additional information to WazzoPay, including:

• Profile photographs
• User preferences
• Marketing preferences
• Participation in competitions or promotions
• Customer reviews
• Product feedback
• Testimonials
• Suggestions for new features

Community engagement activities.

Providing such information is generally optional; however, it may help us personalise your experience and improve our products and services.

You are responsible for ensuring that all information you provide to WazzoPay is accurate, complete, current, and not misleading.

Where your personal information changes, you should promptly update your account or notify WazzoPay so that we can maintain accurate records.

Providing false, incomplete, or misleading information may result in delays, restrictions, suspension of services, or closure of your account where permitted by law or required to meet regulatory obligations.

The information described in this section is collected to enable WazzoPay to:

Verify your identity and comply with Know Your Customer (KYC) obligations.

Prevent fraud, money laundering, terrorist financing, and other financial crimes.

Open and manage your WazzoPay account.

Process payments, transfers, and other financial transactions.

Facilitate access to insurance, lending, and other financial products.

Provide customer support and resolve complaints.

Meet legal, regulatory, and contractual obligations.

Improve the functionality, security, and performance of our products and services.

Develop new products and features.

Personalise your experience.

Communicate important information regarding your account and our services.

Protect the rights, property, safety, and legitimate interests of WazzoPay, our customers, partners, and the public.

WazzoPay will only collect personal information that is reasonably necessary for these purposes or as otherwise permitted or required by applicable law.

When you use WazzoPay, we may automatically collect information about the device you use to access our services.

This may include, but is not limited to:

• Device manufacturer
• Device model
• Device type
• Device identifiers
• Operating system
• Operating system version
• Mobile network provider
• SIM card information (where permitted by applicable law)
• Device language settings
• Time zone
• Screen resolution
• Battery status (where required for fraud detection or application performance)
• Device storage availability
• Browser type and version (for web users)
• Mobile application version
• Device security settings
• Rooted or jailbroken device status
• Device integrity information
• Push notification token

Hardware configuration information.

This information enables WazzoPay to optimise application performance, improve compatibility across devices, detect potentially compromised devices, and strengthen platform security.

To protect customers and maintain platform integrity, WazzoPay may collect unique device identifiers such as:

• Device ID
• Advertising ID (where applicable)
• Android ID
• Apple Identifier for Vendor (IDFV)
• Installation identifiers
• Push notification identifiers

Device fingerprint identifiers generated using fraud prevention technologies.

These identifiers help us:

• Detect suspicious activity
• Prevent multiple fraudulent account registrations
• Secure customer accounts
• Identify compromised devices
• Improve fraud prevention systems

Maintain accurate security records.

WazzoPay does not use device identifiers for unlawful profiling or discriminatory purposes.

Whenever you access WazzoPay, we may automatically collect technical information regarding your connection.

This may include:

• Internet Protocol (IP) address
• Internet Service Provider
• Mobile carrier
• Network type (Wi-Fi, 4G, 5G, etc.)
• Connection speed
• Signal quality
• Domain information
• Browser configuration
• Proxy server usage
• VPN detection
• DNS information
• Session timestamps

Connection history.

This information assists us in:

• Maintaining secure communications
• Detecting suspicious login attempts
• Preventing account compromise
• Identifying unusual network behaviour
• Troubleshooting technical issues

Improving service reliability.

Depending on the services you choose to use, WazzoPay may request permission to access certain features of your device.

These permissions may include access to:

• Camera

Used for:

• Identity verification
• Know Your Customer (KYC)
• QR code payments
• Document scanning
• Insurance claim submissions

Profile photographs.

• Photo Gallery

Used to upload:

• Identity documents
• Insurance claim evidence
• Supporting documentation
• Profile images

Merchant documents.

• Microphone

Where applicable, microphone access may be used for:

• Voice-enabled customer support
• Identity verification

Accessibility services.

• Contacts

With your explicit permission, WazzoPay may access your contacts solely to:

• Facilitate peer-to-peer transfers
• Help identify registered WazzoPay users

Simplify beneficiary selection.

We do not use your contacts for unsolicited marketing.

• SMS

Where permitted by applicable law and with your consent, SMS access may be used to:

• Automatically verify One-Time Passwords (OTPs)
• Improve account verification

Reduce customer friction during registration.

WazzoPay does not read or store your personal text messages except where specifically authorised and necessary for regulatory or security purposes.

• Phone

Where required, limited phone permissions may be requested to:

• Verify device ownership
• Improve fraud prevention

Support secure authentication.

• Storage

Storage access may be required to:

• Save receipts
• Download statements
• Upload supporting documents

Store temporary application files.

• Notifications

Push notifications may be used to inform customers about:

• Payment confirmations
• Incoming transfers
• Security alerts
• Account activity
• Insurance renewals
• Loan repayment reminders

Promotional offers (subject to your communication preferences).

You may manage notification preferences through your device settings or within the WazzoPay application.

When you visit our website or use our digital services, WazzoPay may use cookies, software development kits (SDKs), pixels, local storage technologies, and similar technologies.

These technologies enable us to:

• Authenticate users
• Remember preferences
• Maintain secure sessions
• Prevent fraud
• Analyse application usage
• Improve customer experience
• Measure service performance
• Support analytics

Enhance website functionality.

Cookies may be classified as:

• Essential Cookies
• Functional Cookies
• Security Cookies
• Performance Cookies
• Analytics Cookies

Preference Cookies.

Where required by applicable law, you will be provided with options to manage your cookie preferences.

Subject to your device settings and applicable law, WazzoPay may collect location information to improve security, comply with regulatory obligations, and provide location-based services.

Location information may include:

• GPS coordinates
• Approximate location
• Mobile network location
• Wi-Fi positioning
• Country
• Region
• City

Time zone.

Location data may be used to:

• Detect suspicious transactions
• Prevent account fraud
• Verify transaction authenticity
• Improve customer support
• Enable location-based services

Comply with financial crime regulations.

Where precise location information is not necessary, WazzoPay will use less precise location information wherever reasonably possible.

We automatically collect information regarding how customers interact with WazzoPay.

This may include:

• Features accessed
• Buttons selected
• Pages viewed
• Time spent within the application
• Navigation paths
• Session duration
• Transaction frequency
• Preferred services
• Search history within the application
• Customer interaction patterns

Error messages encountered.

This information enables us to understand customer needs, improve usability, identify service improvements, and enhance overall customer experience.

The information described in this section is collected to:

Maintain the security of the WazzoPay platform.

Detect and prevent fraud, cybercrime, and financial crime.

Authenticate users and devices.

Monitor application performance.

Improve system reliability and stability.

Diagnose technical problems.

Personalise customer experiences.

Develop new products and services.

Improve customer support.

Meet legal and regulatory obligations.

Protect customers, partners, and WazzoPay from unauthorised access, misuse, or abuse.

Strengthen our cybersecurity posture through continuous monitoring and risk assessment.

Automatically collected information forms an important part of WazzoPay's security and fraud prevention framework and helps ensure that our digital financial services remain safe, reliable, and resilient.

To improve the security, usability, and performance of our platform, WazzoPay may collect and analyse information about how customers interact with our services. Behavioural analytics helps us understand usage patterns, identify potential security risks, and enhance the customer experience.

Behavioural information may include:

Navigation patterns within the application.

Time spent on specific screens or features.

Frequency and timing of account access.

Transaction patterns and payment behaviour.

Interaction with notifications and communications.

Feature usage preferences.

Device interaction characteristics.

Authentication behaviour, including login frequency and successful or unsuccessful login attempts.

Session activity and duration.

Response times to security prompts or verification requests.

Behavioural analytics is used to improve our services, strengthen fraud detection capabilities, personalise user experiences where appropriate, and support operational improvements. We do not use behavioural analytics to make unlawful or discriminatory decisions.

WazzoPay may use Artificial Intelligence (AI), machine learning, and other advanced analytical technologies to enhance our products, improve operational efficiency, and strengthen the security of our platform.

These technologies may assist with:

Fraud detection and prevention.

Identity verification.

Risk assessment.

Customer authentication.

Transaction monitoring.

Insurance underwriting support.

Creditworthiness assessments, where applicable.

Customer support automation.

Service personalisation.

Product recommendations.

Operational forecasting.

Cybersecurity monitoring.

Detection of unusual account activity.

AI-assisted tools are designed to support decision-making rather than replace appropriate human oversight. Where required by law or where decisions may have a significant impact on customers, WazzoPay will provide appropriate review mechanisms and comply with applicable legal requirements regarding automated decision-making.

We regularly review our AI models to improve accuracy, reduce bias, enhance fairness, and support responsible innovation.

As a regulated financial technology platform, WazzoPay maintains comprehensive systems to detect, investigate, and prevent fraud, financial crime, money laundering, terrorist financing, sanctions violations, identity theft, cybercrime, and other unlawful activities.

To support these objectives, we may automatically analyse:

Transaction frequency.

Transaction values.

Geographic transaction patterns.

Merchant activity.

Device reputation.

Login behaviour.

Multiple account registrations.

Failed authentication attempts.

Payment patterns.

Wallet funding sources.

Suspicious transaction indicators.

Velocity checks.

Account takeover indicators.

Known fraud intelligence.

Watchlists and sanctions screening results.

Politically Exposed Person (PEP) screening outcomes, where required by law.

Where suspicious activity is detected, WazzoPay may temporarily delay, suspend, decline, or investigate transactions or accounts where permitted or required by applicable law.

To safeguard our customers, partners, employees, and systems, WazzoPay continuously monitors its technology environment for potential cybersecurity threats.

Security monitoring may include:

Detection of unauthorised access attempts.

Network intrusion detection.

Malware and ransomware monitoring.

Application vulnerability monitoring.

Suspicious device activity.

Unusual API requests.

Privileged access monitoring.

Authentication events.

Security event correlation.

Endpoint protection monitoring.

Threat intelligence integration.

Security incident investigations.

Penetration testing results.

Security audit findings.

This information is used solely to maintain the confidentiality, integrity, and availability of WazzoPay's systems and customer information.

To comply with regulatory requirements and support operational accountability, WazzoPay maintains detailed audit logs and security records.

These records may include:

Login history.

Logout history.

Authentication attempts.

Password reset requests.

Changes to account settings.

Device registrations.

Transaction authorisations.

Administrative actions.

API activity.

Customer support actions.

User consent records.

Acceptance of legal agreements.

Account modifications.

Security alerts.

Audit logs help us investigate incidents, resolve disputes, support regulatory reporting, demonstrate compliance, and protect the integrity of our services.

WazzoPay uses secure APIs to integrate with financial institutions, insurers, merchants, payment providers, mobile network operators, government agencies, and other authorised partners.

To ensure the reliability and security of these integrations, we may collect technical telemetry including:

API request and response times.

Error rates.

Authentication events.

API usage volumes.

Transaction throughput.

Performance metrics.

Service availability.

Integration health status.

Technical diagnostics.

Network latency.

System resource utilisation.

Technical telemetry is used to improve platform performance, identify service disruptions, optimise integrations, and maintain secure operations.

When the WazzoPay application experiences unexpected errors or technical issues, we may automatically collect diagnostic information to help identify and resolve the problem.

This information may include:

Application version.

Device model.

Operating system version.

Error codes.

Crash logs.

Memory usage.

Performance statistics.

Network conditions.

Diagnostic identifiers.

Crash reporting information does not intentionally include the content of your financial transactions unless required to diagnose a specific issue and handled in accordance with appropriate security controls.

WazzoPay continually monitors the performance of its services to ensure availability, responsiveness, and reliability.

Performance monitoring may include:

Application response times.

Transaction processing times.

System uptime.

Service interruptions.

Capacity utilisation.

Network performance.

Infrastructure health.

Database performance.

Queue processing.

Cloud service availability.

This information helps us maintain high service standards, improve scalability, and deliver a consistent customer experience.

WazzoPay may use aggregated, anonymised, or de-identified information to understand how customers use our platform and to guide the development of new products and services.

Such information may be used to:

Improve application usability.

Enhance customer journeys.

Introduce new financial products.

Develop new insurance solutions.

Improve payment experiences.

Optimise lending services.

Enhance accessibility features.

Improve customer support.

Identify emerging customer needs.

Support research, innovation, and strategic planning.

Where information has been anonymised so that individuals can no longer be identified, it may be used for analytical and business purposes without identifying any specific customer.

WazzoPay is committed to the responsible and ethical use of automated technologies.

We aim to ensure that:

Automated systems are designed to support fairness, transparency, and accountability.

Decisions with significant legal or financial effects are subject to appropriate governance and, where applicable, human review.

Customers are treated equitably and without unlawful discrimination.

Personal information is processed only for legitimate purposes.

Security and privacy are considered throughout the design, development, and operation of our systems.

We continuously review our automated processes to improve accuracy, reduce unnecessary risks, and support responsible innovation while maintaining compliance with applicable laws and regulatory expectations.

The technologies described in this section support WazzoPay's ability to:

Protect customers and partners from fraud and financial crime.

Maintain the security and resilience of our systems.

Detect and respond to cybersecurity threats.

Improve service quality and reliability.

Support responsible lending and insurance services.

Enhance customer experience.

Meet legal and regulatory obligations.

Strengthen operational efficiency.

Develop innovative financial products and services.

Promote financial inclusion through secure and scalable technology.

WazzoPay will implement appropriate technical, organisational, and governance measures to ensure that advanced technologies are used responsibly, proportionately, and in accordance with applicable privacy and data protection laws.

PART 2B(iii) – MARKETING ANALYTICS, DATA AGGREGATION, CUSTOMER CONTROLS, DATA RETENTION AND AUTOMATED PROCESSING SAFEGUARDS

To help us improve the effectiveness of our communications and ensure customers receive relevant information, WazzoPay may collect information relating to your interactions with marketing and service communications.

This may include:

Whether emails or in-app messages are opened.

Links selected within communications.

Responses to surveys or feedback requests.

Preferences for receiving communications.

Engagement with promotional campaigns.

Redemption of promotional offers or rewards.

Participation in competitions, referrals, or loyalty programmes.

Customer preferences relating to products and services.

We use this information to:

Improve customer communications.

Tailor educational and promotional content.

Measure campaign effectiveness.

Better understand customer interests.

Reduce unnecessary or irrelevant communications.

Where required by law, marketing communications will only be sent with your consent or another lawful basis, and you may withdraw your marketing preferences at any time.

WazzoPay may use software development kits (SDKs), application programming interfaces (APIs), and similar technologies supplied by trusted service providers to support the functionality, security, and performance of our mobile applications and digital services.

These technologies may assist with:

Secure user authentication.

Fraud detection.

Push notifications.

Crash reporting.

Performance monitoring.

Application analytics.

Payment processing.

Identity verification.

Customer support.

Security monitoring.

All third-party technologies used by WazzoPay are subject to appropriate due diligence, contractual safeguards, and applicable data protection requirements.

Where appropriate and permitted by law, WazzoPay may associate information from multiple devices used to access your account.

This enables us to:

Detect unusual account activity.

Prevent account takeover and fraud.

Maintain account security.

Provide a consistent user experience across devices.

Improve customer support.

Support secure authentication processes.

Cross-device recognition is not used to create unnecessary profiles or for unlawful monitoring of customer behaviour.

WazzoPay may combine, aggregate, anonymise, or de-identify information so that it no longer identifies an individual customer.

Aggregated or anonymised information may be used for:

Business intelligence.

Product development.

Statistical reporting.

Operational planning.

Service performance analysis.

Market research.

Regulatory reporting.

Financial inclusion initiatives.

Academic or industry research.

Innovation and service improvement.

Where information has been irreversibly anonymised, it is no longer treated as personal information under this Privacy Policy, provided it cannot reasonably be linked back to an identifiable individual.

WazzoPay takes reasonable steps to maintain the accuracy, completeness, and integrity of information collected automatically.

Our systems may include controls designed to:

Validate incoming data.

Detect inconsistent or corrupted records.

Identify duplicate accounts.

Monitor unusual data patterns.

Improve the quality of analytical information.

Support accurate reporting and decision-making.

Maintaining high-quality data supports better customer service, stronger fraud prevention, and more reliable financial and insurance services.

WazzoPay respects your ability to make informed choices about the collection and use of certain automatically generated information.

Depending on your device, operating system, and applicable law, you may be able to:

Manage location permissions.

Control camera, microphone, contacts, and storage permissions.

Disable non-essential cookies.

Update notification preferences.

Manage marketing preferences.

Restrict advertising identifiers.

Configure browser privacy settings.

Withdraw consent where consent is the legal basis for processing.

Please note that disabling certain permissions or technologies may affect the availability, security, or functionality of some WazzoPay services.

Automatically collected information is retained only for as long as necessary to:

Provide and improve our services.

Protect customers and our platform from fraud and cyber threats.

Comply with legal, regulatory, tax, accounting, and audit obligations.

Resolve disputes and enforce our legal rights.

Support investigations into security incidents or unlawful activities.

Maintain business continuity and operational resilience.

Retention periods are determined according to the nature of the information, legal obligations, regulatory requirements, and legitimate business needs. Where information is no longer required, it will be securely deleted, anonymised, or otherwise disposed of in accordance with WazzoPay's Data Retention Policy.

WazzoPay implements appropriate technical and organisational safeguards to ensure that automatically collected information is processed responsibly and securely.

These safeguards may include:

Encryption of data in transit and, where appropriate, at rest.

Role-based access controls and least-privilege principles.

Multi-factor authentication for authorised personnel.

Security monitoring and logging.

Regular vulnerability assessments and penetration testing.

Secure software development practices.

Data minimisation.

Privacy-by-design and security-by-design principles.

Ongoing monitoring of automated systems.

Periodic reviews of AI models and analytical processes.

Incident response and business continuity procedures.

These measures are designed to protect the confidentiality, integrity, and availability of customer information and to reduce the risk of unauthorised access, disclosure, alteration, or loss.

WazzoPay may engage carefully selected third-party providers to assist with analytics, diagnostics, application performance monitoring, and customer experience improvements.

Where such providers process personal information on our behalf, they are required to:

Process information only in accordance with our documented instructions.

Implement appropriate technical and organisational security measures.

Maintain confidentiality.

Comply with applicable privacy and data protection laws.

Support WazzoPay in meeting its regulatory and contractual obligations.

We do not permit third-party analytics providers to use customer information for their own unrelated commercial purposes.

WazzoPay is committed to continuously improving its products, services, and customer experience. Information collected automatically helps us to:

Enhance system performance and reliability.

Identify and resolve technical issues.

Improve accessibility and usability.

Develop innovative financial and insurance products.

Strengthen fraud detection and cybersecurity capabilities.

Better understand customer needs and service usage trends.

Support financial inclusion initiatives.

Deliver more efficient and secure digital financial services.

Any use of personal information for product improvement will be carried out in accordance with this Privacy Policy, applicable law, and our commitment to responsible data stewardship.

The categories of information described in Part 2B support the secure, reliable, and efficient operation of WazzoPay's digital ecosystem. They enable us to protect customers, detect fraud, improve service quality, maintain regulatory compliance, and develop innovative financial solutions.

Wherever practicable, WazzoPay seeks to limit the collection of automatically generated information to what is necessary for the purposes described in this Privacy Policy. We remain committed to processing such information transparently, proportionately, and in accordance with applicable data protection and financial services laws.

Where WazzoPay partners with banks, payment service providers, or other regulated financial institutions, we may receive information necessary to provide financial services and facilitate secure transactions.

This information may include:

Customer identity verification information.

Bank account details.

Transaction information.

Payment confirmation details.

Account verification responses.

Settlement information.

Financial transaction history.

Payment status updates.

Fraud alerts.

Compliance-related information.

This information enables WazzoPay to:

Facilitate wallet funding and withdrawals.

Process payments.

Support bank integrations through APIs.

Improve transaction reliability.

Reduce fraud risks.

Meet financial regulatory requirements.

Where WazzoPay integrates with mobile network operators, we may receive information necessary to enable mobile-based financial services.

This may include:

Mobile phone number verification.

SIM ownership verification.

Mobile account status.

Mobile money transaction information.

Network authentication information.

Customer verification responses.

This information supports:

Secure account registration.

Customer authentication.

Mobile wallet functionality.

Payment processing.

Fraud prevention.

Improved accessibility for customers using mobile financial services.

As an InsurTech platform, WazzoPay works with insurance companies and underwriting partners to provide accessible digital insurance solutions.

Insurance partners may provide information including:

Policy details.

Insurance coverage information.

Premium payment status.

Claims information.

Underwriting decisions.

Risk assessment information.

Policy renewal information.

Claims investigation information.

Insurance verification results.

This information enables WazzoPay and its insurance partners to:

Provide digital insurance products.

Improve customer onboarding.

Support policy administration.

Facilitate claims processes.

Improve fraud detection.

Deliver personalised insurance experiences.

Insurance information will only be shared and processed according to applicable insurance regulations, contractual agreements, and customer permissions where required.

Where permitted by law, WazzoPay may receive information from government bodies, regulators, or authorised public institutions.

This may include:

Identity verification information.

National identification information.

Tax-related information.

Business registration information.

Licensing information.

Regulatory compliance information.

Public records.

Government-provided information may be used to:

Verify customer identity.

Support customer onboarding.

Prevent identity fraud.

Meet regulatory obligations.

Improve trust and security within the financial ecosystem.

To support secure onboarding and regulatory compliance, WazzoPay may work with authorised identity verification providers.

These providers may supply:

Identity verification results.

Document authenticity checks.

Facial verification results.

Biometric verification results (where legally permitted).

Address verification.

Fraud risk indicators.

Identity confidence scores.

This information helps WazzoPay comply with:

Know Your Customer (KYC) requirements.

Customer Due Diligence (CDD) obligations.

Anti-Money Laundering (AML) regulations.

Fraud prevention requirements.

Where WazzoPay provides or facilitates access to credit products, we may receive information from authorised credit reference agencies, financial institutions, and data providers.

This information may include:

Credit history.

Existing borrowing information.

Repayment history.

Credit scores.

Outstanding obligations.

Financial risk indicators.

Default information.

This information supports:

Responsible lending decisions.

Credit risk assessment.

Fraud prevention.

Customer affordability assessments.

Improved access to suitable financial products.

WazzoPay will process credit-related information responsibly and in accordance with applicable lending and data protection requirements.

Where customers interact with merchants, businesses, or service providers through WazzoPay, we may receive information relating to those transactions.

This may include:

Merchant identification information.

Purchase information.

Payment confirmations.

Invoice information.

Transaction references.

Refund information.

Customer service interactions.

This enables WazzoPay to:

Process payments.

Support merchant services.

Resolve disputes.

Provide transaction records.

Improve payment experiences.

Where WazzoPay enables customers to pay for services such as utilities, government services, education fees, or other payments, we may receive information from relevant providers.

This may include:

Customer account references.

Billing information.

Outstanding balances.

Payment confirmations.

Service status information.

This information allows WazzoPay to provide convenient digital payment solutions and ensure accurate transaction processing.

Where organisations use WazzoPay solutions for payroll, employee payments, benefits, insurance, or financial wellness programmes, we may receive information from authorised employers or organisations.

This may include:

Employee identification details.

Employment information.

Payroll information.

Salary payment details.

Benefits information.

Organisation membership information.

Such information is processed only for agreed purposes and according to applicable contractual arrangements and privacy requirements.

WazzoPay works with trusted technology providers to operate, secure, and improve our platform.

These providers may provide information relating to:

Application performance.

Security monitoring.

Fraud intelligence.

Cloud infrastructure.

Payment processing.

Customer support tools.

Identity verification.

Analytics services.

Technology providers are required to maintain appropriate security standards and process information only according to agreed contractual obligations.

WazzoPay's business model involves collaboration with financial institutions, insurers, merchants, government organisations, and other ecosystem partners to expand access to digital financial services.

Through these partnerships, WazzoPay may receive information necessary to provide:

Embedded insurance.

Digital payments.

Financial services.

Lending solutions.

Merchant services.

Business solutions.

Customer support services.

All partnership arrangements are governed by contractual agreements defining:

Permitted data usage.

Security obligations.

Confidentiality requirements.

Regulatory responsibilities.

Customer protection obligations.

While WazzoPay takes reasonable steps to ensure information received from third parties is reliable, we depend on those third parties to provide accurate and lawful information.

Where appropriate, WazzoPay may:

Validate information received.

Request additional verification.

Allow customers to correct inaccurate information.

Investigate inconsistencies.

Restrict processing where information cannot be verified.

Customers may contact WazzoPay where they believe information received from a third party is inaccurate or incomplete.

WazzoPay applies strict principles when receiving information from third parties.

We ensure that:

Information is collected through lawful channels.

Partners have appropriate authority to share information.

Data sharing is limited to necessary purposes.

Customers are informed where required.

Security controls protect shared information.

Third parties meet applicable regulatory expectations.

WazzoPay does not purchase personal information from unauthorised sources or engage in unlawful data trading.

Information received from third parties allows WazzoPay to:

Expand financial inclusion.

Provide secure digital financial services.

Simplify customer onboarding.

Reduce fraud.

Improve insurance accessibility.

Support responsible lending.

Strengthen payment reliability.

Meet regulatory requirements.

Deliver innovative solutions to underserved communities.

By responsibly connecting banks, insurers, merchants, government services, and customers through a secure digital ecosystem, WazzoPay aims to create a more inclusive and resilient financial environment across Sierra Leone and emerging African markets.

To support secure customer onboarding, identity verification, fraud prevention, and account security, WazzoPay may process biometric information where permitted by applicable laws and regulations.

Biometric information may include:

Facial recognition data.

Selfie verification images.

Facial matching results.

Liveness detection results.

Voice verification information (where applicable).

Other biometric identifiers used for authentication.

Biometric information may be used to:

Confirm customer identity.

Prevent identity theft.

Reduce fraudulent account creation.

Secure customer accounts.

Support regulatory Know Your Customer (KYC) requirements.

Improve customer onboarding processes.

WazzoPay applies additional safeguards to biometric information, including:

Restricted access.

Encryption and secure storage.

Controlled processing environments.

Limited retention periods.

Monitoring of access activity.

Where required, WazzoPay will obtain appropriate customer consent before collecting biometric information.

Where customers access insurance products, particularly health, life, travel, or other protection products, WazzoPay may process health-related information necessary for underwriting, policy administration, claims management, and customer support.

Health information may include:

Medical declarations.

Health questionnaires.

Medical history information provided by customers.

Information required for insurance eligibility assessments.

Medical documentation supporting insurance claims.

Healthcare-related supporting documents.

Health information may be processed:

To provide insurance products requested by customers.

To support insurance underwriting decisions.

To assess and process legitimate claims.

To comply with insurance regulatory obligations.

To support fraud prevention.

Health information will only be accessed by authorised personnel, insurance partners, healthcare providers, or service providers where necessary and legally permitted.

As part of WazzoPay's embedded insurance ecosystem, customers may submit information relating to insurance claims.

Claims-related information may include:

Claim details.

Incident descriptions.

Supporting documentation.

Photographs or videos.

Proof of loss.

Medical reports where applicable.

Police reports where required.

Assessment reports.

Claim investigation records.

This information is used to:

Process insurance claims.

Detect fraudulent claims.

Support fair claim assessments.

Improve insurance services.

Meet regulatory requirements.

Where claims are managed by insurance partners, information will be shared securely according to contractual agreements and applicable insurance regulations.

Because WazzoPay serves underserved communities, including informal workers, small businesses, farmers, and financially excluded individuals, we recognise that some customers may experience financial vulnerability.

Where necessary and lawful, WazzoPay may process information relating to:

Income levels.

Employment status.

Financial commitments.

Household circumstances.

Ability to meet repayment obligations.

Transaction behaviour.

Access to essential services.

Financial hardship indicators.

This information may be used to:

Support responsible lending.

Avoid inappropriate financial products.

Improve financial inclusion.

Provide suitable services.

Identify customers requiring additional support.

WazzoPay does not use financial vulnerability information to unfairly discriminate against customers.

As a financial technology provider operating within a regulated environment, WazzoPay may process information required to meet financial crime prevention obligations.

This may include:

Identity verification results.

Customer risk ratings.

Transaction monitoring results.

Suspicious activity indicators.

Source of funds information.

Source of wealth information where required.

Sanctions screening results.

Politically Exposed Person (PEP) screening information.

Regulatory reporting information.

This information helps WazzoPay:

Prevent financial crime.

Protect customers.

Meet regulatory obligations.

Cooperate with authorised regulators and law enforcement agencies where legally required.

To comply with financial crime regulations, WazzoPay may screen customers against:

Politically Exposed Persons databases.

Sanctions lists.

Fraud databases.

Regulatory enforcement databases.

Other legally authorised compliance databases.

Where a potential match is identified, WazzoPay may conduct additional verification and enhanced due diligence.

A customer's identification as a PEP or sanctions-related match does not automatically mean services will be refused. Decisions will be based on applicable laws, regulatory requirements, and risk assessments.

WazzoPay recognises the importance of protecting children's information.

Unless specifically permitted by law and appropriately designed, WazzoPay does not intentionally provide financial services directly to children below the legally permitted age.

Where information relating to children is processed, such as:

Education payments.

School fee payments.

Insurance beneficiaries.

Family financial products.

WazzoPay will ensure that such information is:

Collected only where necessary.

Processed lawfully.

Protected with appropriate safeguards.

Accessed only by authorised individuals.

Where required, parental or guardian consent may be obtained.

WazzoPay is committed to responsible financial inclusion and recognises that some customers may require additional protection.

Customers may be considered vulnerable due to circumstances such as:

Financial hardship.

Limited digital literacy.

Limited access to technology.

Disability.

Age-related challenges.

Emergency circumstances.

Where appropriate, WazzoPay may process relevant information to:

Provide additional support.

Improve accessibility.

Prevent customer harm.

Deliver appropriate financial solutions.

Such information will always be handled sensitively and confidentially.

Where WazzoPay uses automated technologies, including AI and machine learning, to analyse sensitive information, we apply additional governance measures.

These may include:

Data minimisation.

Model monitoring.

Human oversight where appropriate.

Bias testing.

Security controls.

Access restrictions.

Regular reviews.

AI-assisted processes are designed to support responsible financial inclusion and improve service delivery while protecting customer rights.

WazzoPay applies enhanced protection measures when processing special categories of personal information.

These measures may include:

Encryption.

Strong authentication requirements.

Role-based access controls.

Data segregation.

Audit logging.

Secure transmission methods.

Employee confidentiality obligations.

Partner security requirements.

Regular security assessments.

Access to sensitive information is limited strictly to individuals and systems that require such access for legitimate purposes.

Customers may have rights regarding their sensitive personal information, including:

Requesting information about how it is used.

Requesting correction of inaccurate information.

Requesting deletion where legally permitted.

Withdrawing consent where consent is the legal basis.

Requesting restrictions on processing.

Raising concerns or complaints.

These rights may be subject to legal and regulatory requirements, particularly where information must be retained for financial crime prevention, regulatory reporting, or legal obligations.

WazzoPay is committed to processing sensitive personal information responsibly, transparently, and securely.

We recognise that trust is fundamental to financial inclusion. Customers who rely on WazzoPay services must have confidence that their personal, financial, health, and identity information is handled with the highest level of care.

By applying enhanced safeguards, responsible technology practices, and strong governance controls, WazzoPay aims to create a secure digital financial ecosystem that protects customers while expanding access to essential financial and insurance services.

Excellent. We will now complete Part 2 – Information We Collect with Part 2E – Data Accuracy, Customer Responsibilities and Information Management.

This section is important because financial institutions, regulators, and partners need assurance that customer information is not only collected securely but is also accurate, reliable, current, and responsibly managed.

For WazzoPay, this is particularly important because inaccurate information could impact:

• KYC verification,
• payment processing,
• insurance underwriting,
• claims decisions,
• loan assessments,
• fraud prevention,

regulatory reporting.

Below is the next section.

Customers rely on WazzoPay to provide secure access to financial and insurance services. To do this effectively, we require customers to provide accurate and truthful information.

Accurate information helps WazzoPay to:

Verify customer identity.

Protect accounts against fraud.

Process payments correctly.

Provide suitable insurance products.

Support responsible lending decisions.

Complete regulatory checks.

Communicate important service information.

Maintain accurate financial records.

Provide effective customer support.

Providing inaccurate or incomplete information may affect the availability, quality, or suitability of WazzoPay services.

When registering for or using WazzoPay services, customers are responsible for ensuring that all information provided is:

Accurate.

Complete.

Current.

Truthful.

Not misleading.

Provided through lawful means.

Customers must not:

Provide false identity information.

Use another person's identity without authorisation.

Submit fraudulent documents.

Misrepresent financial circumstances.

Provide inaccurate information for insurance, lending, or payment purposes.

Providing false or misleading information may result in:

Delayed verification.

Restricted account functionality.

Suspension of services.

Rejection of applications.

Investigation for suspected fraud.

Reporting to relevant authorities where legally required.

Customers should update their personal information whenever there are changes to ensure that WazzoPay maintains accurate records.

Customers may need to update information relating to:

Contact details.

Residential address.

Employment information.

Business information.

Identification documents.

Bank account information.

Beneficiary information.

Insurance details.

Financial circumstances.

Customers may update certain information directly through the WazzoPay application or by contacting customer support.

Where updates involve regulated information, WazzoPay may require additional verification before changes are approved.

To protect customers and maintain compliance with financial regulations, WazzoPay may verify information provided by customers.

Verification activities may include:

Checking identity documents.

Confirming information against authorised databases.

Validating bank or mobile money details.

Performing biometric verification.

Conducting fraud screening.

Requesting supporting documentation.

Verification processes may be conducted directly by WazzoPay or through approved third-party verification providers.

WazzoPay maintains data quality processes designed to improve the accuracy, reliability, and integrity of customer information.

These controls may include:

Automated validation checks.

Duplicate record detection.

Identity verification processes.

Data consistency checks.

Transaction reconciliation.

Regular system reviews.

Exception monitoring.

Quality assurance reviews.

These measures help ensure that customer information remains reliable throughout its lifecycle.

Certain information collected by WazzoPay may be used to support financial assessments, insurance services, and risk management activities.

This may include information used for:

Insurance eligibility assessments.

Premium calculations.

Risk profiling.

Fraud prevention.

Loan affordability assessments.

Credit risk evaluation.

Transaction monitoring.

Customers acknowledge that providing accurate information is essential to ensuring fair and appropriate outcomes.

Where automated systems are used, WazzoPay will apply appropriate governance, security controls, and oversight measures.

Customers are responsible for maintaining the confidentiality and security of their account credentials and authentication information.

Customers should:

Keep passwords confidential.

Protect One-Time Passwords (OTPs).

Avoid sharing authentication information.

Report suspicious activity immediately.

Use secure devices when accessing WazzoPay.

Review account activity regularly.

WazzoPay will never request customers to disclose confidential authentication information through unofficial channels.

If customers believe that information held by WazzoPay is inaccurate, incomplete, outdated, or incorrect, they may contact us through available customer support channels.

Upon receiving a request, WazzoPay may:

Review the information.

Investigate the concern.

Request supporting documentation.

Correct inaccurate information where appropriate.

Explain why information cannot be changed where legal restrictions apply.

We aim to resolve data accuracy requests promptly and fairly.

WazzoPay manages customer information throughout the entire relationship lifecycle, including:

• Customer Onboarding

Information is collected, verified, and securely stored.

• Service Delivery

Information is used to provide payments, insurance, lending, and other financial services.

• Account Management

Information is updated and maintained to ensure accuracy.

• Risk Management

Information supports fraud prevention, compliance monitoring, and security controls.

• Customer Support

Information enables efficient communication and issue resolution.

• Account Closure

Information is securely retained or deleted according to applicable legal and regulatory requirements.

WazzoPay retains personal information only for as long as necessary to:

Provide services.

Maintain transaction records.

Meet regulatory obligations.

Support audits.

Prevent fraud.

Resolve disputes.

Enforce agreements.

Protect legal rights.

Retention periods may vary depending on:

The type of information.

Regulatory requirements.

Financial services obligations.

Insurance requirements.

Legal obligations.

Business needs.

When information is no longer required, WazzoPay will securely delete, anonymise, or dispose of it using appropriate methods.

WazzoPay maintains governance processes to ensure responsible management of customer information.

These processes may include:

Data ownership responsibilities.

Access controls.

Privacy reviews.

Security assessments.

Staff confidentiality obligations.

Partner due diligence.

Data protection training.

Compliance monitoring.

We maintain accountability for how customer information is collected, processed, stored, shared, and protected.

WazzoPay recognises that trust is fundamental to financial inclusion.

Many of the communities we serve—including informal workers, small businesses, farmers, market traders, and underserved individuals—may be accessing digital financial services for the first time.

By maintaining accurate, secure, and responsibly managed information, WazzoPay aims to:

Protect customers.

Expand access to financial services.

Improve financial resilience.

Deliver reliable digital experiences.

Build confidence in Sierra Leone's emerging digital economy.

We use your information to create, manage, and maintain your WazzoPay account.

This includes:

Registering new customers.

Verifying identity and completing customer onboarding.

Managing account profiles.

Authenticating users.

Maintaining account security.

Updating customer information.

Providing access to available WazzoPay services.

Managing account preferences.

Communicating important account information.

This enables customers to securely access WazzoPay's digital financial ecosystem.

As a digital wallet provider, WazzoPay uses customer information to deliver secure electronic payment services.

This includes:

Creating and maintaining digital wallets.

Processing deposits and withdrawals.

Managing wallet balances.

Enabling peer-to-peer transfers.

Facilitating merchant payments.

Supporting QR code payments.

Processing digital transactions.

Generating payment confirmations.

Maintaining transaction records.

Providing account statements.

Transaction information is used to ensure payments are processed accurately, securely, and efficiently.

WazzoPay uses information necessary to execute and manage financial transactions.

This may include:

Verifying sender and recipient details.

Authenticating transactions.

Processing payment instructions.

Confirming transaction status.

Managing failed or disputed transactions.

Processing refunds where applicable.

Maintaining financial records.

Supporting reconciliation activities.

We may share necessary transaction information with authorised financial partners, banks, payment processors, merchants, or regulators where required to complete transactions or meet legal obligations.

As an InsurTech platform, WazzoPay uses customer information to provide accessible insurance solutions through authorised insurance partners.

Information may be used to:

Recommend suitable insurance products.

Complete insurance onboarding.

Assess insurance eligibility.

Support digital underwriting.

Calculate risk profiles.

Generate insurance quotations.

Process premium payments.

Manage policy information.

Support renewals.

Facilitate claims processing.

Improve insurance accessibility.

Our objective is to simplify insurance access by using digital technology to reduce barriers traditionally experienced by underserved communities.

Where applicable, WazzoPay may use artificial intelligence, machine learning, and automated analytical tools to support insurance underwriting and risk assessment.

These technologies may analyse information such as:

Customer-provided information.

Transaction behaviour.

Insurance history.

Relevant risk indicators.

Product-specific information.

Other lawful data sources.

AI-assisted tools may help:

Improve underwriting speed.

Reduce manual processing.

Detect potential fraud.

Improve pricing accuracy.

Provide faster insurance decisions.

Automated tools are designed to support responsible decision-making and operate alongside appropriate governance and oversight processes.

Where WazzoPay provides or facilitates access to lending products through authorised partners, we may use information to support responsible credit decisions.

This may include:

Assessing eligibility.

Reviewing affordability.

Understanding repayment capacity.

Assessing financial behaviour.

Supporting credit scoring.

Managing loan applications.

Monitoring repayments.

Providing repayment reminders.

Managing customer accounts.

WazzoPay seeks to promote responsible lending practices and avoid providing unsuitable financial products.

One of WazzoPay's core objectives is expanding access to financial services for underserved communities, including:

Informal sector workers.

Market traders.

Farmers.

Micro and small businesses.

Women-led enterprises.

Low-income households.

Where legally permitted, WazzoPay may analyse alternative financial indicators to better understand customer needs.

These may include:

Payment behaviour.

Wallet activity.

Business activity.

Utility payment history.

Transaction patterns.

Financial engagement.

This helps WazzoPay create more inclusive financial products for individuals who may have limited access to traditional banking services.

WazzoPay uses personal information to protect customers, partners, and the wider financial ecosystem from fraud and financial crime.

This includes:

Detecting suspicious transactions.

Monitoring unusual activity.

Preventing account takeover.

Identifying fraudulent behaviour.

Conducting identity verification.

Performing AML/KYC checks.

Screening against relevant compliance databases.

Investigating suspected fraud.

Reporting suspicious activity where legally required.

Protecting customers and maintaining trust in digital finance is a fundamental responsibility of WazzoPay.

WazzoPay uses customer information to understand user needs and improve how customers interact with our services.

This includes:

Simplifying customer journeys.

Improving application usability.

Providing faster services.

Personalising experiences.

Identifying customer challenges.

Improving accessibility.

Developing customer support solutions.

Our objective is to make digital financial services simple, affordable, and accessible for all users.

We use personal information to provide effective customer support.

This includes:

Responding to enquiries.

Resolving complaints.

Investigating disputes.

Providing technical assistance.

Communicating service updates.

Supporting account recovery.

Improving support quality.

Customer communications may be monitored or recorded where necessary for quality assurance, security, training, and regulatory purposes.

WazzoPay uses information to develop, test, and improve new products and services.

This may include:

Improving existing features.

Developing new financial products.

Testing new technologies.

Enhancing security capabilities.

Improving insurance solutions.

Creating better tools for SMEs.

Expanding financial inclusion initiatives.

Where possible, information used for innovation and research will be aggregated or anonymised.

WazzoPay may analyse customer information to understand:

Product usage.

Service performance.

Customer needs.

Market trends.

Operational efficiency.

Financial inclusion impact.

Analytics help us make informed decisions and continuously improve our services.

Where analytics involve personal information, appropriate safeguards will be applied.

WazzoPay uses personal information to comply with applicable legal and regulatory obligations.

This includes:

Bank of Sierra Leone requirements.

Anti-Money Laundering obligations.

Counter Terrorist Financing requirements.

Customer identification requirements.

Tax obligations.

Audit requirements.

Regulatory reporting.

Law enforcement requests where legally authorised.

Compliance obligations are essential to maintaining a safe and trusted financial ecosystem.

We may use personal information to protect:

Customers.

Employees.

Partners.

Systems.

Business operations.

Legal rights.

This may include:

Investigating security incidents.

Enforcing agreements.

Defending legal claims.

Preventing misuse of services.

Protecting against cyber threats.

Where permitted and based on appropriate consent or lawful grounds, WazzoPay may use information to provide:

Service updates.

Product information.

Educational content.

Financial awareness materials.

Relevant offers.

Promotional communications.

Customers can manage their communication preferences and opt out of marketing communications at any time.

WazzoPay uses information responsibly to support its broader mission of expanding access to financial and insurance services.

Through responsible data use, WazzoPay aims to:

Reduce barriers to financial services.

Support underserved communities.

Improve access to insurance protection.

Enable digital payments.

Empower small businesses.

Promote economic participation.

Build financial resilience.

Information is used not only to operate our platform, but to help create a more inclusive digital economy.

WazzoPay is committed to ensuring that customer information is used responsibly, transparently, and securely.

We will:

Only use information for legitimate purposes.

Limit access to authorised individuals.

Protect customer confidentiality.

Maintain appropriate security measures.

Respect customer rights.

Continuously improve our privacy practices.

Trust is central to our relationship with customers, and responsible data use is fundamental to achieving our goal of delivering secure and inclusive financial services.

Before sharing customer information, WazzoPay applies the following principles:

• Transparency

Customers are informed about how their information may be shared through this Privacy Policy and relevant service agreements.

• Purpose Limitation

Information is only shared for specific, legitimate purposes.

• Data Minimisation

We only share information that is necessary and relevant.

• Security Protection

Information is shared using appropriate technical and organisational safeguards.

• Partner Accountability

Third parties receiving information must comply with agreed privacy, security, and confidentiality obligations.

• Regulatory Compliance

All information sharing activities must comply with applicable laws and regulations.

WazzoPay may share information with authorised banks and financial institutions to support payment, settlement, account verification, and financial services.

This may include:

Customer identification information.

Transaction information.

Payment instructions.

Account verification details.

Settlement information.

Fraud-related information.

Sharing with banking partners enables:

Wallet funding.

Withdrawals.

Bank transfers.

Payment processing.

Account reconciliation.

Secure financial transactions.

Banks and financial institutions receiving information are required to handle customer information according to applicable financial services and data protection requirements.

WazzoPay partners with insurance companies to provide embedded digital insurance solutions.

We may share relevant information with authorised insurers to support:

Insurance onboarding.

Policy creation.

Underwriting.

Premium collection.

Claims processing.

Policy administration.

Renewal management.

Fraud prevention.

Information shared may include:

Identity information.

Contact details.

Insurance application information.

Risk-related information.

Claims information.

Payment information.

Insurance partners remain responsible for their own regulatory obligations as insurance providers and must maintain appropriate security and confidentiality controls.

Where WazzoPay integrates with mobile network operators and telecommunications providers, information may be shared to support:

Mobile authentication.

Mobile money transactions.

Customer verification.

Payment processing.

Account security.

Service delivery.

Examples of information shared may include:

Mobile phone number.

Verification details.

Transaction references.

Authentication responses.

Such sharing enables customers to access financial services through widely available mobile infrastructure.

WazzoPay may work with authorised payment processors and financial technology providers to deliver secure payment services.

Information may be shared to support:

Transaction processing.

Payment routing.

Fraud monitoring.

Settlement activities.

Technical support.

Payment reconciliation.

Service providers are required to:

Protect customer information.

Use information only for agreed purposes.

Maintain security controls.

Comply with contractual obligations.

Where customers use WazzoPay to pay merchants, businesses, or service providers, relevant transaction information may be shared.

This may include:

Payment confirmation.

Transaction reference.

Customer name where necessary.

Payment status.

Refund information.

This enables merchants to:

Confirm payments.

Deliver goods or services.

Process refunds.

Resolve transaction disputes.

Merchants are not permitted to use customer information for unrelated purposes without appropriate legal authority or consent.

WazzoPay may share information with government bodies, regulators, and authorised public institutions where required by law or regulation.

This may include sharing information with:

Financial regulators.

Tax authorities.

Law enforcement agencies.

Courts and legal authorities.

Government service providers.

Information may be shared for purposes including:

Regulatory reporting.

Fraud investigations.

Financial crime prevention.

Compliance monitoring.

Legal obligations.

WazzoPay will only provide information when legally authorised or required.

Where WazzoPay provides or facilitates lending services, information may be shared with authorised credit reference agencies.

This may include:

Loan applications.

Repayment information.

Credit history.

Default information.

Credit assessment information.

This supports:

Responsible lending.

Credit risk management.

Fraud prevention.

Improved access to financial services.

Customers will be informed where credit reporting obligations apply.

WazzoPay uses trusted technology providers to operate, maintain, and improve its platform.

These providers may support:

Cloud hosting.

Data storage.

Cybersecurity.

Application monitoring.

Customer support systems.

Analytics.

Software infrastructure.

Technology providers may access customer information only where necessary to provide contracted services.

They must:

Maintain confidentiality.

Implement security safeguards.

Process information according to WazzoPay instructions.

Comply with applicable privacy obligations.

WazzoPay uses secure API integrations to connect with financial institutions, insurers, payment providers, and other ecosystem partners.

API-based information sharing enables:

Real-time payments.

Account verification.

Insurance services.

Digital onboarding.

Transaction processing.

Automated service delivery.

API integrations are designed using security best practices, including:

Authentication controls.

Encryption.

Access restrictions.

Monitoring.

Logging.

Secure data transmission.

Only authorised information necessary for the specific service is exchanged.

WazzoPay may collaborate with strategic partners to develop and deliver innovative financial services.

Partners may include:

Banks.

Insurance companies.

Microfinance institutions.

SMEs.

Government programmes.

Development organisations.

Financial inclusion initiatives.

Information shared with partners will be limited to agreed purposes and protected through appropriate contractual arrangements.

WazzoPay may share information with authorised organisations to prevent:

Fraud.

Cybercrime.

Identity theft.

Financial crime.

Account misuse.

This may include sharing information with:

Fraud prevention providers.

Security partners.

Financial institutions.

Regulators.

Law enforcement authorities.

Such sharing helps protect customers and maintain trust in digital financial services.

If WazzoPay undergoes a business transaction, information may be transferred as part of:

A merger.

Acquisition.

Investment process.

Partnership restructuring.

Sale of assets.

Any receiving organisation will be required to respect customer privacy obligations and continue protecting customer information.

As WazzoPay grows and works with international technology providers, development partners, investors, and financial service providers, customer information may be processed outside Sierra Leone.

Where international transfers occur, WazzoPay will ensure:

Appropriate safeguards are implemented.

Data protection requirements are considered.

Third parties maintain adequate security standards.

Customer information remains protected.

Where customer consent is required, WazzoPay will provide appropriate choices regarding information sharing.

Customers may:

Review applicable permissions.

Withdraw consent where permitted.

Request information about data sharing activities.

Contact WazzoPay regarding privacy concerns.

Certain information sharing cannot be withdrawn where required for:

Regulatory compliance.

Fraud prevention.

Legal obligations.

Transaction processing.

All organisations receiving customer information from WazzoPay must:

Use information only for authorised purposes.

Protect confidentiality.

Maintain security controls.

Follow applicable privacy laws.

Prevent unauthorised access.

Notify WazzoPay of security incidents where required.

WazzoPay conducts appropriate due diligence before partnering with organisations that process customer information.

WazzoPay believes that responsible collaboration is essential to expanding financial inclusion.

By securely connecting customers with banks, insurers, merchants, regulators, and technology providers, WazzoPay aims to:

Increase access to financial services.

Reduce barriers for underserved communities.

Enable affordable insurance protection.

Support small businesses.

Improve digital payment adoption.

Build a trusted financial ecosystem.

Customer trust remains central to every partnership and every data-sharing decision made by WazzoPay.

WazzoPay maintains a security governance framework designed to ensure that information security remains a core business priority.

Our governance approach includes:

Defined security responsibilities.

Information security policies.

Data protection procedures.

Risk management processes.

Access governance.

Security monitoring.

Incident management procedures.

Regular security reviews.

Security responsibilities are assigned across relevant teams to ensure accountability for protecting customer information.

WazzoPay incorporates privacy and security considerations throughout the development lifecycle of its products and services.

This means security controls are considered during:

Product design.

Software development.

API integration.

System architecture.

Feature development.

Partner onboarding.

Data processing activities.

Rather than adding security after systems are developed, WazzoPay seeks to build secure practices into the foundation of its technology ecosystem.

WazzoPay uses encryption technologies designed to protect customer information during storage and transmission.

Encryption measures may include:

Encryption of data transmitted between customers, applications, and systems.

Protection of sensitive information stored within databases.

Secure communication protocols.

Encryption key management practices.

Encryption helps reduce the risk of unauthorised access if information is intercepted or accessed improperly.

WazzoPay follows secure software development practices to reduce technology risks.

Our development approach may include:

Secure coding standards.

Code reviews.

Security testing.

Vulnerability assessments.

Controlled software releases.

Environment separation.

Dependency monitoring.

Application security testing.

Software updates and improvements are managed through controlled processes designed to protect system reliability and security.

Because WazzoPay operates within an interconnected financial ecosystem, secure API management is essential.

Our API security controls may include:

Secure authentication mechanisms.

Encryption of API communications.

Access tokens and authorisation controls.

API monitoring.

Rate limiting.

Activity logging.

Partner access restrictions.

Regular security reviews.

API connections with banks, insurers, mobile network operators, payment providers, and other partners are designed to ensure that information is exchanged securely and only for approved purposes.

WazzoPay implements measures designed to protect customer accounts from unauthorised access.

Security measures may include:

Strong customer authentication.

Password protection.

One-Time Password (OTP) verification.

Device authentication.

Session monitoring.

Login activity monitoring.

Account recovery controls.

Suspicious activity detection.

Customers are encouraged to protect their account credentials and report suspicious activity immediately.

Access to customer information is restricted based on business requirements and the principle of least privilege.

WazzoPay applies controls including:

Role-based access controls.

User authentication requirements.

Access approval processes.

Access monitoring.

Periodic access reviews.

Employees, contractors, and authorised service providers are required to maintain confidentiality and only access information necessary to perform their responsibilities.

WazzoPay applies data minimisation principles by collecting and processing only information necessary for legitimate business purposes.

We seek to:

Limit unnecessary data collection.

Separate sensitive information where appropriate.

Restrict access based on necessity.

Remove information that is no longer required.

This reduces privacy risks and strengthens overall information protection.

WazzoPay uses technology-enabled controls to help protect customers and prevent fraudulent activities.

Fraud prevention measures may include:

Transaction monitoring.

Behavioural analysis.

Risk scoring.

Suspicious activity detection.

Identity verification.

Device monitoring.

Automated fraud alerts.

These controls help protect customers while maintaining a secure digital financial ecosystem.

Where WazzoPay uses artificial intelligence and machine learning technologies, appropriate safeguards are applied to ensure responsible use.

AI security measures may include:

Controlled access to AI systems.

Monitoring of model performance.

Protection of training data.

Testing for accuracy and reliability.

Human oversight where appropriate.

Review of potential bias or unfair outcomes.

AI systems are designed to support better service delivery while respecting customer privacy and rights.

WazzoPay may use secure cloud infrastructure providers to operate its technology platform.

Cloud security measures may include:

Secure infrastructure configuration.

Identity and access management.

Network protection.

Monitoring and logging.

Backup controls.

Disaster recovery capabilities.

Security updates.

Cloud service providers are selected based on appropriate security and reliability considerations.

WazzoPay maintains monitoring capabilities designed to identify and respond to security risks.

Monitoring activities may include:

System activity monitoring.

Security event logging.

Transaction monitoring.

Access monitoring.

Threat detection.

Performance monitoring.

Security logs may be maintained to support:

Investigations.

Compliance reviews.

Incident response.

Security improvement.

WazzoPay regularly reviews its technology environment to identify and address security weaknesses.

Security activities may include:

Vulnerability assessments.

Penetration testing.

Security reviews.

Code security analysis.

Configuration assessments.

Third-party security reviews.

Identified issues are prioritised and addressed based on risk levels.

As a digital wallet provider, WazzoPay applies controls designed to protect payment transactions.

Security measures may include:

Transaction authentication.

Fraud monitoring.

Secure payment processing.

Transaction verification.

Payment reconciliation.

Secure record keeping.

Where payment card information is processed, WazzoPay seeks to align with applicable payment security standards and industry best practices.

WazzoPay recognises that people are an important part of cybersecurity.

Employees and authorised personnel may receive training relating to:

Data protection.

Privacy responsibilities.

Cybersecurity awareness.

Fraud prevention.

Secure handling of information.

Incident reporting.

Confidentiality obligations apply to anyone authorised to access customer information.

WazzoPay evaluates third-party service providers that process customer information.

Third-party assessments may consider:

Security practices.

Data protection commitments.

Compliance requirements.

Access controls.

Incident response capabilities.

Partners and service providers must maintain appropriate safeguards and comply with contractual obligations.

WazzoPay maintains processes to identify, investigate, manage, and respond to security incidents.

In the event of a suspected data breach, WazzoPay may:

Investigate the incident.

Contain and mitigate risks.

Assess affected information.

Restore affected services.

Notify relevant parties where required.

Implement corrective actions.

Where legally required, affected customers and relevant authorities will be notified.

WazzoPay maintains resilience measures designed to support continued service availability.

These may include:

Data backups.

Recovery procedures.

System redundancy.

Operational resilience planning.

Disaster recovery processes.

The objective is to minimise disruption and maintain reliable access to essential financial services.

WazzoPay is committed to continuously improving its security posture.

As the platform grows, WazzoPay aims to align its security practices with recognised industry frameworks, including where applicable:

ISO 27001 information security principles.

PCI DSS payment security principles.

Secure software development practices.

Financial services cybersecurity standards.

Security controls are reviewed regularly to respond to evolving cyber threats.

While WazzoPay implements strong security measures, customers also play an important role in protecting their information.

Customers should:

Keep passwords confidential.

Protect OTP codes.

Avoid sharing account access.

Use trusted devices.

Update applications regularly.

Report suspicious activity.

Avoid fraudulent links or communications.

Customers should immediately notify WazzoPay if they believe their account has been compromised.

Security is central to WazzoPay's commitment to financial inclusion.

We understand that many customers using WazzoPay may be accessing digital financial services for the first time.

By implementing strong security controls, responsible technology practices, and continuous improvement processes, WazzoPay aims to provide a trusted platform where individuals, businesses, and communities can confidently access digital payments, insurance, lending, and financial services.

Customers have the right to understand how their personal information is collected, used, stored, and shared.

WazzoPay provides information through:

This Privacy Policy.

Terms and Conditions.

Product disclosures.

Consent notices.

In-app notifications.

Customer communications.

We aim to provide information in a clear and understandable manner so customers can make informed decisions about using WazzoPay services.

Customers have the right to request information about the personal data WazzoPay holds about them.

A customer access request may include:

Confirmation that personal information is being processed.

Categories of personal information held.

The purposes for processing.

Information about third parties with whom information may be shared.

Copies of relevant personal information where appropriate.

Before providing access, WazzoPay may require identity verification to protect customer confidentiality.

Customers have the right to request correction of inaccurate, incomplete, or outdated personal information.

Customers may request updates to:

Personal details.

Contact information.

Identification information.

Business information.

Financial information.

Insurance-related information.

WazzoPay will review correction requests and take reasonable steps to update inaccurate information where appropriate.

Customers may request deletion of personal information where permitted by applicable law.

Deletion requests may be considered where:

Information is no longer required.

Processing was based on consent that has been withdrawn.

There is no valid legal basis for continued processing.

However, WazzoPay may retain certain information where required for:

Regulatory obligations.

Financial transaction records.

Anti-money laundering requirements.

Fraud prevention.

Legal claims.

Audit requirements.

Where information cannot be deleted due to legal obligations, WazzoPay will explain the reason.

Customers may request that WazzoPay limit the processing of their personal information in certain circumstances.

Examples may include:

Where accuracy of information is disputed.

Where processing is being challenged.

Where information is no longer required but must be retained for legal purposes.

When processing is restricted, WazzoPay will only process information where permitted by law.

Customers may object to certain uses of their personal information where permitted by applicable laws.

This may include objections relating to:

Certain marketing activities.

Certain forms of profiling.

Processing based on legitimate interests.

WazzoPay will review objections and determine whether processing can continue based on legal, regulatory, or operational requirements.

Where WazzoPay relies on customer consent as the legal basis for processing personal information, customers may withdraw that consent at any time.

Withdrawal of consent may apply to:

Marketing communications.

Optional data permissions.

Certain personalised services.

Optional analytics activities.

Withdrawal of consent does not affect processing that:

Occurred before withdrawal.

Is required by law.

Is necessary to provide contracted services.

Where applicable and technically feasible, customers may request their personal information in a structured and commonly used format.

This may include information relating to:

Account details.

Transaction history.

Payment records.

Customer-provided information.

Data portability requests may be subject to security verification and applicable legal limitations.

Because WazzoPay may use artificial intelligence, machine learning, and automated systems to support services such as:

Insurance underwriting.

Fraud detection.

Risk assessment.

Financial product recommendations.

Customers may have rights relating to automated processing.

Where required, WazzoPay will provide:

Information about automated processing.

Appropriate explanations of relevant processes.

Opportunities for review where decisions significantly affect customers.

WazzoPay is committed to responsible AI practices, including appropriate oversight and monitoring.

Customers have control over how they receive marketing communications from WazzoPay.

Customers may:

Subscribe to promotional communications.

Unsubscribe from marketing messages.

Update communication preferences.

Choose preferred communication channels.

Customers may still receive essential service communications, including:

Security alerts.

Transaction confirmations.

Regulatory notices.

Account-related messages.

Customers can manage certain permissions granted to the WazzoPay application through their device settings.

Permissions may include:

Camera access.

Location access.

Notifications.

Contacts.

Storage access.

Customers should understand that restricting certain permissions may affect functionality, particularly features requiring identity verification, security checks, or location-based services.

WazzoPay obtains consent in a clear, transparent, and meaningful manner where consent is required.

Consent mechanisms may include:

Registration acceptance.

Digital consent forms.

In-app permissions.

Product-specific disclosures.

Electronic confirmation.

Customers will be informed about:

What information is being collected.

Why it is required.

How it will be used.

Who it may be shared with.

How consent can be withdrawn.

Certain WazzoPay services may require specific consent before information is processed.

Examples include:

• Insurance Services

Consent may be required for:

Insurance applications.

Health-related information.

Claims processing.

Underwriting assessments.

• Lending Services

Consent may be required for:

Credit assessments.

Financial analysis.

Credit bureau checks.

• Payment Services

Consent may be required for:

Account linking.

Payment authorisation.

Transaction processing.

WazzoPay recognises that some customers may have limited digital experience or require additional assistance.

We aim to support customers through:

Clear explanations.

Accessible communication.

Customer support channels.

Educational resources.

Fair treatment practices.

Customers should not be disadvantaged because of limited digital literacy or unfamiliarity with technology.

Customers wishing to exercise their privacy rights may contact WazzoPay through official customer support channels.

Requests should include:

Customer name.

Account details.

Description of the request.

Supporting information where required.

WazzoPay may request identity verification before processing requests.

This helps protect customers from unauthorised requests.

WazzoPay aims to respond to privacy requests within reasonable timeframes.

Response times may depend on:

Complexity of the request.

Number of requests received.

Verification requirements.

Legal obligations.

If additional time is required, WazzoPay will provide appropriate communication.

Customers who believe their privacy rights have been affected may raise concerns with WazzoPay.

Complaints may relate to:

How information has been used.

Unauthorised access.

Information sharing concerns.

Failure to respect privacy choices.

WazzoPay will:

Investigate complaints fairly.

Provide updates where appropriate.

Take corrective action where required.

Improve processes to prevent recurrence.

Where customers remain dissatisfied after contacting WazzoPay, they may have the right to raise concerns with relevant regulatory or data protection authorities.

This may include relevant financial regulators, data protection authorities, or other competent bodies depending on the nature of the complaint.

WazzoPay believes customers should remain at the centre of decisions involving their personal information.

By providing transparency, privacy controls, and meaningful choices, WazzoPay aims to build a trusted financial ecosystem where customers can confidently access:

Digital payments.

Insurance solutions.

Lending services.

Financial tools.

Business services.

Respecting customer privacy is fundamental to WazzoPay's mission of expanding secure and inclusive financial access.

Cookies are small data files stored on a customer's device when accessing digital services.

Although cookies are commonly associated with websites, similar technologies are also used within mobile applications, including:

Mobile SDKs.

Device identifiers.

Application tokens.

Local storage technologies.

Tracking pixels.

Analytics tools.

Authentication technologies.

These technologies allow applications to recognise devices, maintain secure sessions, and improve service functionality.

WazzoPay uses cookies and similar technologies for several important purposes.

These include:

• Security and Authentication

To:

Verify customer identity.

Maintain secure login sessions.

Detect suspicious access attempts.

Protect accounts from unauthorised use.

• Application Performance

To:

Monitor system reliability.

Identify technical problems.

Improve application speed.

Optimise customer experience.

• Fraud Prevention

To:

Detect unusual behaviour.

Identify suspicious devices.

Prevent account takeover.

Support transaction monitoring.

• Personalisation

To:

Remember customer preferences.

Improve service recommendations.

Provide more relevant experiences.

• Analytics and Improvement

To:

Understand how customers use services.

Identify areas for improvement.

Develop better products.

WazzoPay may use the following categories of technologies.

Essential technologies are necessary for the operation and security of WazzoPay services.

They support:

Customer authentication.

Account access.

Secure transactions.

Application functionality.

Session management.

Without these technologies, certain core services may not function correctly.

Examples include:

Login session management.

Security tokens.

Authentication identifiers.

WazzoPay uses security-related technologies to protect customers and prevent misuse.

These technologies may help detect:

Suspicious login activity.

Unusual transaction patterns.

Device anomalies.

Fraud attempts.

Automated attacks.

Security technologies may collect information such as:

Device characteristics.

Network information.

Application activity.

Login patterns.

This information supports WazzoPay's fraud prevention and cybersecurity processes.

Analytics technologies help WazzoPay understand how customers interact with our services.

Information collected may include:

Features used.

Application performance.

User journeys.

Error reports.

Service interactions.

Analytics help us:

Improve usability.

Identify technical issues.

Develop better services.

Improve customer experiences.

Where possible, analytics information is aggregated or anonymised.

Functional technologies allow WazzoPay to remember customer preferences and provide improved experiences.

Examples may include:

Language preferences.

Display settings.

Communication preferences.

Previously selected options.

These technologies help reduce unnecessary repetition and improve convenience.

Where permitted, WazzoPay may use certain technologies to understand engagement with communications.

These may help us measure:

Whether communications are opened.

Customer engagement.

Campaign effectiveness.

Responses to offers.

Marketing technologies are only used in accordance with applicable consent requirements and customer preferences.

Because WazzoPay operates primarily through mobile applications, we may use certain technical identifiers associated with devices.

These may include:

Device identifiers.

Application installation identifiers.

Operating system information.

Device model information.

Security status information.

Network information.

These identifiers help WazzoPay:

Secure accounts.

Detect fraudulent devices.

Improve application performance.

Provide reliable services.

Where customers provide permission, WazzoPay may use location-related information to support certain services.

Location information may assist with:

Fraud prevention.

Security verification.

Service availability.

Merchant experiences.

Location-based features.

Customers may manage location permissions through their device settings.

Certain services may be affected if location access is disabled.

To protect customers and the integrity of the WazzoPay ecosystem, we may use device recognition technologies.

Device information may include:

Device configuration.

Application settings.

Security characteristics.

Network information.

Behavioural signals.

This helps us:

Recognise trusted devices.

Detect suspicious activity.

Prevent fraudulent access.

Protect customer accounts.

Device recognition information is used for security purposes and is not intended to identify customers beyond legitimate service requirements.

WazzoPay may use automated technologies, including artificial intelligence and machine learning tools, to analyse security signals.

These technologies may assist with:

Fraud detection.

Risk assessment.

Transaction monitoring.

Service optimisation.

Customer protection.

AI-supported monitoring is subject to appropriate governance, security controls, and human oversight where appropriate.

WazzoPay may use carefully selected third-party service providers that provide technology supporting:

Application performance.

Cybersecurity.

Analytics.

Cloud infrastructure.

Payment processing.

Identity verification.

Third-party providers are required to:

Protect customer information.

Follow agreed instructions.

Maintain appropriate security standards.

Process information only for approved purposes.

Customers may have options to manage certain tracking technologies through:

Mobile device settings.

Application permissions.

Browser settings where applicable.

Communication preferences.

Customers should note that disabling certain technologies may affect:

Application functionality.

Security features.

Authentication processes.

Personalised services.

Essential security technologies cannot always be disabled because they are required to operate financial services safely.

Where consent is required, WazzoPay will provide customers with appropriate information before using non-essential technologies.

Customers will have the opportunity to:

Accept optional technologies.

Decline optional technologies.

Update preferences.

Withdraw consent where applicable.

Consent choices will be respected and managed securely.

Information collected through cookies and similar technologies is retained only for as long as necessary.

Retention periods depend on:

The purpose of collection.

Security requirements.

Regulatory obligations.

Business needs.

When information is no longer required, it will be securely deleted, anonymised, or disposed of.

WazzoPay applies security measures to protect information collected through digital technologies.

These may include:

Encryption.

Access controls.

Monitoring.

Secure storage.

Data minimisation.

Restricted access.

Only authorised individuals and systems may access such information where necessary.

WazzoPay recognises that transparency is essential when using digital technologies.

We are committed to:

Clearly explaining technology usage.

Respecting customer preferences.

Protecting customer information.

Using technology responsibly.

Improving customer security.

Our use of cookies and tracking technologies is designed to create a safer, faster, and more reliable digital financial experience.

As a fintech and insurtech company, WazzoPay uses technology to remove barriers to financial access.

Responsible use of digital technologies enables us to:

Protect customers.

Improve accessibility.

Reduce fraud.

Deliver faster services.

Support financial inclusion.

Technology remains central to our mission of empowering individuals, businesses, and underserved communities through secure digital financial solutions.