Privacy Policy

1. Introduction

TruPay ("TruPay," "we," "us," or "our") provides a mobile application and related services (together, the "App") that help informal lenders — shopkeepers, savings-circle organizers, small landlords, and similar community lenders — digitize the credit and repayment records they already keep, and that use those records to build a trust ranking network.

TruPay is a record-keeping and trust-network tool. TruPay is not a lender: it does not originate, fund, or collect loans. Any credit is arranged directly between the people who use the App.

This Privacy Policy explains what information we collect, how we use and share it, and the choices and rights available to you. It applies wherever the App is used, regardless of country. It is written to be understood by anyone, not only by lawyers, and it is not limited to any single country's legal requirements.

2. Who We Are

TruPay is the data controller responsible for the information described in this Policy. You can reach us using the contact details at the end of this document.

3. Scope of This Policy

This Policy covers:

• The TruPay mobile application, available on Android (and, when applicable, iOS);
• Any related websites, APIs, or services that link to this Policy.

It does not cover third-party services that TruPay does not control, even if you access them through the App (for example, your phone's own messaging or WhatsApp app, which the App may open so you can send an invitation or a reminder). We encourage you to review the privacy policies of any third-party service you use alongside TruPay.

4. Information We Collect

4.1 Information you provide directly

• Account and login information: your email address, which you use to sign in by receiving a one-time code; your name; your phone number; and your national identity document number together with its issuing country. We use the document number to identify you and to prevent duplicate accounts — we do not use it to query any external identity database, and we do not collect an image or photograph of the document itself.
• Verification information: the one-time codes we send to your email to confirm that you control the account.
• Lending and repayment records you enter: credit you extend to others, savings-circle (rotating credit association) contributions and payouts, rent or informal loan payments, due dates, amounts, and notes you choose to record.
• Ratings and rankings: the ratings, comments, or trust markers you give to other people in your network based on their payment behavior.
• Contacts (with your permission): if you choose to grant contact access, we process the phone numbers in your contact list to identify which of your contacts are already on TruPay, to help you invite others, and to record a loan for someone. We use contacts only for these purposes. You can decline this permission, or revoke it later in your device settings, and still use the rest of the App's core features.

4.2 Information collected automatically

• Device and app data: device model, operating system version, app version, and language settings.
• Push notification token: a token issued by the mobile platform's push service so we can deliver notifications to your device — for example, when someone sends you a loan to confirm or confirms one of your payments.
• Log and diagnostic data: IP address, timestamps, and similar technical data generated when the App communicates with our servers, together with error and crash information used to keep the App working.

We do not collect precise device location (GPS); we do not request photographs of government identity documents; we do not use device-attestation or carrier/SIM-based verification services; and we do not use third-party advertising or analytics software development kits. If any of this changes in the future, we will update this Policy and, where required by law, ask for your permission before doing so.

4.3 Information about other people that you submit

Because TruPay's core purpose is to digitize records that lenders already keep about other people, information you enter about a customer, savings-circle member, tenant, or borrower — such as their name, phone number, and payment history — is also personal information, even though that person may never open the App themselves. See Section 12 for how we handle this.

4.4 Information from third parties

We may receive limited information from our service providers in order to operate the App — for example, delivery or bounce confirmations from our email provider. See Section 7.2 for the categories of providers we use.

5. How We Use Information

We use the information described above to:

• Provide the App's core functionality: tracking credit, savings-circle contributions, and payments, and giving you totals and reminders;
• Verify your identity and secure your account against fraud and impersonation;
• Calculate trust rankings and scores based on the repayment behavior recorded by lenders in the network;
• Communicate with you, including sending one-time sign-in codes, service notices, and, where you have agreed, product updates;
• Maintain, troubleshoot, and improve the App;
• Detect, investigate, and prevent fraud, abuse, or activity that violates our terms;
• Comply with applicable law and respond to lawful requests from public authorities.

6. How the Trust Network Works

TruPay's product is a peer-ranked trust network: people are ranked based on how they have actually repaid credit extended to them by shopkeepers, savings-circle organizers, and landlords who already know them. This is the central purpose of the App, and it means that repayment and ranking information about a person can be visible within the network to the people connected to them.

We do not sell your information to advertisers, we do not use it for third-party advertising, and we do not currently share your repayment or ranking information with outside organizations. If in the future we decide to make trust or repayment data available to third parties (for example, to help organizations make credit decisions), we will update this Policy and provide notice before that sharing begins.

7. How We Share Information

We do not sell your personal information, and we do not currently share it with outside organizations for their own purposes. We share information only in the following circumstances:

7.1 Service providers

We share information with vendors who process it on our behalf under contract, including:

7.2 Legal and safety reasons

We may disclose information if required by law, regulation, legal process, or governmental request, or where we believe disclosure is necessary to protect the rights, property, or safety of TruPay, our users, or others.

7.3 Business transfers

If TruPay is involved in a merger, acquisition, financing, or sale of assets, information may be transferred as part of that transaction, subject to this Policy or a policy at least as protective.

7.4 With your direction

We may share information in other ways if you direct us to do so or provide your consent.

8. Data Retention

Because TruPay's purpose is to preserve a durable record of repayment behavior within the network, repayment and ranking records are generally retained for as long as they remain useful for that purpose, or as required by applicable law, whichever is longer. Account information is retained for as long as your account is active.

You can delete your account at any time from within the App (see Section 11). When you do, we delete your profile and the records associated with your account. Because a loan or a rating necessarily involves another person, deleting these records may also remove the corresponding entry from the other person's view of the network. We may retain or anonymize limited information where the law requires us to keep it, and we will explain this if it applies to your request.

9. Data Security

We use technical and organizational safeguards designed to protect information against unauthorized access, alteration, disclosure, or destruction, including encryption in transit and access controls. No method of storage or transmission is completely secure, and we cannot guarantee absolute security.

10. International Data Transfers

TruPay operates across multiple countries, and our service providers may store or process information in countries other than the one where you live. Where we transfer personal information across borders, we take steps intended to ensure it receives a comparable level of protection to that described in this Policy, using contractual or other safeguards recognized under applicable data protection law.

11. Your Rights and Choices

Subject to the law that applies to you, you may have rights to:

• Access the personal information we hold about you;
• Correct inaccurate or incomplete information;
• Delete your account and associated personal information — directly in the App under My profile → Delete my account, or by contacting us — subject to Section 8;
• Object to or restrict certain uses of your information;
• Receive a copy of your information in a portable format;
• Withdraw consent where our use of your information is based on consent (for example, contact access), without affecting the lawfulness of processing before withdrawal.

To exercise any of these rights, contact us using the details in Section 15. We may need to verify your identity before fulfilling a request, and some requests may be limited where information also concerns other people in the trust network or where retention is required by law.

12. Information About People Who Are Not App Users

Because lenders use TruPay to record real-world credit relationships, the App will contain information about people — customers, savings-circle members, tenants, borrowers — who may never install the App or create an account themselves.

• The person entering the information (for example, a shopkeeper or savings-circle organizer) is responsible for having a legitimate basis, under applicable law, to record and share information about the people they transact with, in the same way they would be responsible for keeping accurate records in a paper notebook.
• A person who is described in a TruPay record but does not hold an account may contact us using the details in Section 15 to ask what information concerns them, request a correction, or object to its inclusion. We will respond in accordance with applicable law and will balance such requests against the integrity of the trust network and the rights of the lenders who submitted the record.

13. Children's Privacy

The App is intended for adults who lend, borrow, or organize informal credit arrangements, and is not directed at children. We do not knowingly collect personal information from children under the age of consent applicable in their country (generally 13 to 16, depending on jurisdiction). If we learn that we have collected such information without appropriate consent, we will take steps to delete it.

14. Changes to This Policy

We may update this Policy from time to time to reflect changes in the App, our practices, or legal requirements. We will update the "Last updated" date above, and where changes are significant, we will provide additional notice, such as an in-app message, before the changes take effect.

15. Contact Us

If you have questions about this Policy or wish to exercise any of the rights described above, contact us at:

TruPay
Email: privacy@trupay.network
Website: trupay.network