KogoPAY’s privacy policy describes how we use your data and to describe how Personally Identifiable Information (PII) is being used. Please read our privacy policy carefully to get a clear understanding of how we collect, use, protect or otherwise handle your Personally Identifiable Information.

Why do we collect and use your personal information?
We collect and use your data primarily so that we can identify you correctly when you register with our service and when you login and use our service. KogoPAY is subject to the rules and regulations of GDPR 2018.

During the registration process we will collect your:

1) Name
2) Surname
3) Date of birth
4) Address
5) Phone number
6) Email
7) Capture your identity document and a ‘selfie’.

Once you are registered, at first login we will ask for your phone number, date of birth along with the PIN you chose during registration. This is a two-factor process to make sure it is you that is logging in.

What happens if I do not provide my personal information?
We need your personal information in order to provide our money transfer service to you. If we do not collect your personal information we will not be able to provide our services to you.

How do we protect your information?
At KogoPAY information security is a high priority. Our technology is based on best-in-class standards and access to personal information is only for the strict purposes of what it is intended. We scan for malware. Your personal information is contained behind secured networks and is only accessible by a limited number of persons who have special access rights to such systems, and are required to keep the information confidential. In addition, all sensitive information you supply is encrypted via Secure Socket Layer (SSL) technology.

Who will we share your personal information with?
We will share your personal information with the corresponding money service business who will pay your transferred funds to your selected recipient.

Transferring your personal information outside Europe
We will share your personal information with money service businesses outside Europe in the circumstances that you send money outside of Europe and they require your personal information to pay your transferred funds to your selected recipient. We enter into a written contract with third-party money service business(es) that we will share your personal information with and they contractually undertake to protect your personal information. We will only share information with entities where it is necessary to do so for the operation of your account and where that entity provides security, at least equal to our own and meets the requirements of GDPR 2018.

How long will we store your personal information?
We will store your personal information for up to six years after the end of our relationship with you.. This is to enable us to refer to our records in the unlikely event that you want to lodge a complaint against us within six years. We may be required by a regulator or other legal body to hold information for longer.

What are your rights in relation to your personal information?

Right to access
You have the right to request copies of the personal information we hold about you at any time.

Right to rectification
You have the right to request that we correct any inaccurate personal information we hold about you.

Right to erasure
You have the right to request that we delete your personal information from our records.

Please note that we will not be able to delete your personal information whilst we are still providing our services to you. We will be able to delete your personal information once you cancel the service or once the service is completed.

Right to restrict processing
You have the right to request that we restrict how we use your personal information.

Right to object
You have the right to object to the collection and use of your personal information at any time.

Right to data portability
You have the right to obtain a copy of your personal information in a legible and compatible format such as Excel or Word.

Right to be forgotten
You have the right to request that as far as possible we “forget ” you and your information.

How can I exercise my rights in relation to my personal information?
You can exercise all of your rights by contacting us at support@kogopay.com

How do I lodge a complaint about the use of my personal information?
You can lodge a complaint with us directly by contacting us on one of the above contact details.

You also have the right to lodge a complaint directly with the Information Commissioner’s Office (ICO). The ICO are the regulator who makes sure that we use your personal information in a lawful way.

You can lodge a complaint with the ICO by following this link https://ico.org.uk/concerns/ or calling the ICO on 0303 123 1113.

Updates and Changes
We reserve the right, at any time, to add to, change, update, or modify this Policy, simply by posting such change, update, or modification on the Site and without any other notice to you. Any such change, update, or modification will be effective immediately upon posting on the Site. It is your responsibility to review this Policy from time to time to ensure that you continue to agree with all of its terms.

Contacting Us
If there are any questions regarding this privacy policy, you may contact us at support@kogopay.com