Privacy Policy

Payol is a product of Instant LTD, a company registered in the Republic of Rwanda, which owns and runs it. Instant LTD ("Payol", "we", "us") is the data controller responsible for the personal data described here. This policy covers account holders and their teammates, the payers who pay through Payol pages, the people account holders pay, and visitors to our website.

It explains what we collect, why, who we share it with and how long we keep it, in line with Rwanda's law on the protection of personal data and privacy (Law N° 058/2021). Our Terms & Conditions explain how Payol works.

If you have an account

• Your name, phone number and email, and how you sign in (one-time codes, Google, or an optional password, which we store only as a secure hash).
• Activation details: your business name and address, account type, registration certificate and TIN for businesses, and photos of your ID or passport and a selfie holding it.
• Your payout accounts: mobile money numbers and their network.
• What you create and do in Payol: payment links, invoices, customers, payout links, wallet lines, withdrawals, refunds, notification settings and webhooks.
• Your business brand: logo, brand color, support contacts and the images you upload.

If you pay or receive money through Payol

• The mobile money number you pay from or receive on, its network, and whether you confirmed it is yours.
• The details the business asks for on its page, such as your name, phone number, email and answers to its questions.
• The amount, reference, date and status of each payment, refund or payout.

For everyone

• Messages you send us and the messages we send you by SMS, WhatsApp or email.
• Technical data: IP address, device and browser, pages visited, and logs of sign-ins and sensitive actions. We use it to keep Payol secure, for example to limit how often a number can receive payment prompts.

We never ask for, see or store your mobile money PIN. You approve payments on your own phone, with your network.

• To run Payol: create your pages, take payments, hold your balance, send payouts and withdrawals, and show you every line in your wallet.
• To verify accounts before they can move money, and to prevent fraud, money laundering and other misuse.
• To send receipts, codes, reminders and the notifications you choose.
• To answer your questions and help when something goes wrong.
• To keep Payol secure, fix problems and improve the product.
• To meet our legal, tax and accounting obligations and answer lawful requests from authorities.

We rely on our agreement with you, our legal obligations and our legitimate interest in running a safe payment service. Where the law needs your consent, we ask for it, and you can withdraw it at any time.

We don't sell personal data. We share it only when we need to:

• Mobile money networks and our payment partner, to request payments, send payouts and confirm their status.
• A number-lookup provider, which tells us the name registered on a mobile money number, so a business can check it before paying it.
• The business you pay, which sees your payment and the details its page asked for. A business that pays you sees whether the money arrived or you claimed it, the network, and whether you confirmed your number.
• Service providers that host and run Payol for us: cloud hosting and file storage, and email, SMS and WhatsApp delivery. They may only use the data to provide their service to us. Our analytics and error monitoring tools get metrics only, never personal information (see below).
• Your teammates, who see the account's links, invoices, customers and wallet according to their role.
• Authorities, when the law requires it, for example to prevent money laundering or to answer a court order.
• A buyer or successor, if Instant LTD is reorganised, merged or sold, under the same protections.

Public pages never show your balance, other payers or internal identifiers.

We use two tools, and both collect metrics only, never personal information:

• Google Analytics, on our public website only, to count visits and see which pages people read. It doesn't run in the Payol app or on payment, invoice, payout or receipt pages, and Google's advertising features are turned off.
• Sentry, to tell us when something in Payol breaks and how fast pages load. Before an error report leaves Payol, we remove who you are, your IP address, cookies, what you typed or sent, and the codes and identifiers in web addresses. Session recordings are off.

We never send them your name, phone number, email, payments, documents or messages.

ID photos, selfies and registration certificates are kept in private storage, never at a public address, and only the people who review activations can open them. We use them to verify your account and to meet our legal obligations, and for nothing else.

• Account details, for as long as your account is open.
• Transactions (payments, refunds, payouts, withdrawals, money added and every wallet line), permanently, even after your account closes. They are never edited or deleted.
• Identity records, for as long as anti-money-laundering, tax and accounting rules require, even after your account closes.
• Payers' and recipients' details, as part of the transactions of the business they paid or were paid by.
• The activity log of sign-ins and sensitive actions, for 360 days, then it is deleted.
• Other technical data, only as long as we need it to protect Payol.

When we no longer need data, we delete it or make it anonymous.

Connections to Payol are encrypted. Sensitive secrets, such as webhook signing keys, are encrypted at rest. Withdrawals, new payout accounts and payout links need a one-time code, access inside Payol follows each person's role, and sensitive actions are logged. No system is perfectly secure; if a breach affects your personal data, we'll tell you and the authorities as the law requires.

You can ask us to:

• give you a copy of your personal data, or send it to another service;
• correct data that's wrong or incomplete;
• delete your data, unless the law requires us to keep it;
• stop or limit some uses of your data, or review a decision made only by automated means.

Email [email protected] from the address on your account. We may need to confirm it's you. If you aren't happy with our answer, you can complain to the National Cyber Security Authority, which supervises personal data protection in Rwanda.

We use cookies to keep you signed in and secure; Payol doesn't work without them. On our public website, Google Analytics also sets cookies to count visits. You can block or delete cookies in your browser settings, but you'll be signed out of Payol.

Some of our service providers store or process data outside Rwanda. When they do, we transfer it only as the law allows, with safeguards suited to each provider.

Accounts are for people aged 18 or over. We don't knowingly collect data from children for an account; if you think a child has opened one, tell us and we'll close it.

We may update this policy as Payol changes. We'll tell you by email or in the app before an important change takes effect.

Instant LTD, Republic of Rwanda. Questions or requests about your data: [email protected].