Privacy Policy

Effective Date: January 23, 2025

Last Updated: January 23, 2025

1. Introduction

MannaTransfer ("we," "our," or "us") operates a mobile application and related services that enable users to send money internationally. This Privacy Policy describes how we collect, use, disclose, and protect your information when you use our mobile application and services (collectively, the "Services").

By using our Services, you agree to the collection and use of information in accordance with this Privacy Policy.

2. Information We Collect

2.1 Personal Information

We collect information you provide directly to us, including:

• Account Information: Name, email address, phone number, date of birth, nationality, and residential address
• Identity Verification (KYC): Government-issued ID (passport, driver's license, national ID), photographs, selfies, and biometric data for identity verification
• Financial Information: Bank account details, debit/credit card information, mobile wallet information
• Transaction Information: Transfer amounts, recipient details, transaction history, and purpose of transfers
• Recipient Information: Names, addresses, phone numbers, and bank/wallet details of your transfer recipients

2.2 Automatically Collected Information

When you use our Services, we automatically collect:

• Device Information: Device type, operating system, unique device identifiers, and mobile network information
• Usage Data: App features accessed, time spent in app, crash reports, and performance data
• Location Data: With your consent, approximate location for fraud prevention and to find nearby cash pickup locations
• Log Data: IP address, browser type, access times, and referring URLs

2.3 Information from Third Parties

We may receive information about you from:

• Identity verification service providers
• Financial institutions and payment processors
• Credit bureaus and fraud prevention services
• Public databases for compliance purposes

3. How We Use Your Information

We use the information we collect to:

• Provide Services: Process money transfers, manage your account, and deliver customer support
• Verify Identity: Comply with Know Your Customer (KYC) and Anti-Money Laundering (AML) regulations
• Prevent Fraud: Detect, investigate, and prevent fraudulent transactions and unauthorized access
• Comply with Laws: Meet legal and regulatory requirements, including reporting obligations
• Improve Services: Analyze usage patterns to enhance user experience and develop new features
• Communicate: Send transaction confirmations, security alerts, and service updates
• Marketing: With your consent, send promotional communications about our services

4. How We Share Your Information

We may share your information with:

4.1 Service Providers

• Payment processors (e.g., Mastercard) to execute transfers
• Identity verification providers to validate your identity
• Cloud hosting providers to store data securely
• Customer support platforms to assist you

4.2 Financial Partners

• Banks and financial institutions to complete transfers
• Mobile money operators for wallet transfers
• Cash pickup agents for cash collection services

4.3 Legal and Regulatory

• Government authorities when required by law
• Regulatory bodies for compliance purposes
• Law enforcement agencies for fraud investigations

4.4 Business Transfers

In the event of a merger, acquisition, or sale of assets, your information may be transferred to the acquiring entity.

5. Data Security

We implement industry-standard security measures to protect your information:

• Encryption: All data is encrypted in transit (TLS 1.2+) and at rest (AES-256)
• Secure Storage: Sensitive data is stored in secure, access-controlled systems
• Authentication: Multi-factor authentication and biometric security options
• Monitoring: Continuous monitoring for unauthorized access and suspicious activity
• Compliance: Adherence to PCI-DSS, SOC 2, and other security standards

6. Data Retention

We retain your information for as long as necessary to:

• Provide our Services to you
• Comply with legal obligations (typically 5-7 years for financial records)
• Resolve disputes and enforce agreements
• Prevent fraud and abuse

When information is no longer needed, we securely delete or anonymize it.

7. Your Rights and Choices

Depending on your location, you may have the following rights:

• Access: Request a copy of your personal information
• Correction: Update or correct inaccurate information
• Deletion: Request deletion of your information (subject to legal retention requirements)
• Portability: Receive your data in a portable format
• Opt-out: Unsubscribe from marketing communications
• Withdraw Consent: Revoke previously given consent

To exercise these rights, contact us at privacy@mannatransfer.com.

8. International Data Transfers

Your information may be transferred to and processed in countries other than your own. We ensure appropriate safeguards are in place, including:

• Standard contractual clauses approved by relevant authorities
• Data processing agreements with all service providers
• Compliance with applicable data protection laws

9. Children's Privacy

Our Services are not intended for individuals under 18 years of age. We do not knowingly collect information from children. If you believe we have collected information from a child, please contact us immediately.

10. Third-Party Links

Our app may contain links to third-party websites or services. We are not responsible for the privacy practices of these third parties. We encourage you to review their privacy policies.

11. Push Notifications

With your consent, we send push notifications for:

• Transaction confirmations and status updates
• Security alerts and suspicious activity warnings
• Service announcements and updates
• Promotional offers (optional)

You can manage notification preferences in your device settings or within the app.

12. Biometric Data

If you enable biometric authentication (Face ID/Touch ID):

• Biometric data is processed locally on your device
• We do not store or transmit biometric data to our servers
• You can disable biometric authentication at any time in app settings

13. Changes to This Policy

We may update this Privacy Policy from time to time. We will notify you of material changes by:

• Posting the updated policy in the app
• Sending you a notification or email
• Updating the "Last Updated" date above

Your continued use of the Services after changes indicates acceptance of the updated policy.

14. California Privacy Rights (CCPA)

California residents have additional rights under the CCPA:

• Right to know what personal information is collected and how it's used
• Right to delete personal information
• Right to opt-out of the sale of personal information (we do not sell your data)
• Right to non-discrimination for exercising privacy rights

15. European Privacy Rights (GDPR)

If you are in the European Economic Area, you have rights under GDPR including:

• Right to access, rectify, or erase your data
• Right to restrict or object to processing
• Right to data portability
• Right to lodge a complaint with a supervisory authority