SaylorPay Privacy Policy

How We Collect, Use, and Protect Your Information

Effective Date: June 30, 2025
Last Updated: December 31, 2025

1. Introduction

Coinsaylor Solutions ("Coinsaylor Solutions", "SaylorPay", "we", "us", "our") is committed to protecting the privacy and personal data of individuals and businesses in accordance with applicable data protection laws and regulations. This Privacy Policy explains how we collect, use, store, share, and protect personal information when you use SaylorPay products and services.

This Privacy Policy applies to:

Important: SaylorPay does not hold, store, or transfer user funds. All funds remain within your mobile money account on your SIM card. We act as a facilitator to automate interactions between you and your mobile money provider.

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

2. Definitions

For the purposes of this Privacy Policy:

3. Scope of Services

SaylorPay currently operates in Ghana and supports mobile money services on MTN Ghana, Telecel Ghana, and AirtelTigo Ghana.

Key Service Principles:

4. Information We Collect

The personal data we collect depends on how you interact with us, the services you use, and the choices you make. We collect information from different sources including information you provide directly, information collected automatically, and data we infer or generate from other data.

4.1 Information You Provide Directly or Authorize

App User Data

Phone Number

Mobile Money Transaction SMS Messages

Important: SaylorPay does not access personal conversations or unrelated SMS messages by default.

Merchant / Developer Data

Identity Data

Contact Data

Financial Data

Transactional Data

4.2 Information Automatically Collected

App User Data

Technical/Log Data

App Usage Data

Purpose: This information is essential for ensuring security, reliability, performance monitoring, troubleshooting, and continuous improvement of our services.

Merchant / Developer Data

Server Logs and Technical Data

Transaction Metadata

Marketing and Communications Data

Anonymized and Aggregate Data

4.3 Transaction and Activity History

Each time you perform a mobile money action within SaylorPay, a record is securely logged against your phone number (if synced) and made available within your private online dashboard via our website.

History Includes:

Purpose: To enable you to track transaction history across multiple networks, review past actions for record-keeping, and support dispute resolution and fraud prevention.

5. App Permissions and Data Access

SaylorPay requests certain device permissions to provide its core features. These permissions are used only when required, only for the stated purposes, and within the scope described below.

5.1 Accessibility Services Usage

What It Does: SaylorPay requires Android Accessibility Services to automate USSD interactions that are explicitly initiated by you.

How We Use It:

What We Don't Do:

Important: Without enabling Accessibility Services, SaylorPay's core USSD automation features will not function. All USSD interactions are processed locally on your device. We do not store, transmit, or share USSD content with any third party.

5.2 SMS (Short Message Service)

Purpose: SaylorPay accesses mobile money-related SMS messages to support transaction processing, verification, and record keeping.

How We Use SMS Access:

  1. Payment Confirmation & Verification

    • To confirm whether a payment is successful or failed
    • To match payments to merchant orders
    • To provide accurate feedback to customers and merchants

  2. Transaction History & Record Keeping

    • To create a centralized transaction history across all supported networks
    • To display your mobile money transactions in one place
    • To include transactions initiated through SaylorPay or directly via USSD

  3. Security, Dispute Resolution & Fraud Prevention

    • To verify transactions initiated from your device
    • To protect both you and SaylorPay in cases of disputes, errors, or false claims
    • To ensure accurate investigation when issues arise

Optional SMS Forwarding (User-Controlled): SaylorPay includes an optional SMS forwarding toolkit that allows users or merchants to forward selected SMS messages to:

This feature:

Important Notice:

Privacy Commitment:

5.3 Phone (Call & Device State)

Purpose: SaylorPay requires Phone permission to automate USSD-based transactions initiated by you.

How We Use This Permission:

Important:

5.4 Camera

Purpose: SaylorPay uses the device camera to support the Scan to Pay feature.

How We Use This Permission:

Important:

5.5 Contacts

Purpose: SaylorPay requests access to contacts to improve convenience when initiating transactions.

How We Use This Permission:

Important:

5.6 Background Processing & Foreground Services

To ensure reliable processing of transaction notifications and optional SMS forwarding, SaylorPay may process financial SMS messages in the background using Android foreground services. This ensures uninterrupted service and prevents the operating system from terminating essential processes.

Purpose: To maintain app functionality and prevent interruption of critical services.

6. Data Protection & User Control

All permissions are used strictly within the scope of their stated purpose.

7. How We Use Your Information

We process your personal information to operate and improve our products, fulfill our contractual obligations, comply with legal requirements, and enhance your experience, based on legitimate business interests and your consent where required.

7.1 App User Data Processing

Each purpose relies on one or more of the following legal bases:

7.1.1 To Facilitate Account Creation and Management

We use your phone number and mobile network selection to:

Legal Basis: Fulfillment of contract, Legitimate business interests

7.1.2 To Deliver and Facilitate Services

We use your device information to:

Legal Basis: Fulfillment of contract, Legitimate business interests

7.1.3 To Monitor, Secure, and Improve Our Product

We use device and log data to:

Legal Basis: Legitimate business interests, Compliance with legal obligations

7.1.4 To Send Administrative and Service-Related Communications

We may use your information to:

Legal Basis: Fulfillment of contract, Legal obligations, Legitimate business interests

7.1.5 To Respond to User Inquiries and Provide Support

We use your personal and transaction information to:

Legal Basis: Fulfillment of contract, Legitimate business interests

7.1.6 To Enforce Our Terms, Conditions, and Policies

We use your information to:

Legal Basis: Fulfillment of contract, Legal obligations, Legitimate business interests

7.1.7 To Respond to Legal Requests and Prevent Harm

If required by law or legal proceedings, we may access and review your personal data to:

Legal Basis: Legal obligations, Legitimate business interests

7.1.8 For Other Business and Analytical Purposes

We may use anonymized and aggregated device, log, and activity data for:

Note: This data is processed in a way that does not identify individual users unless explicit consent is provided.

Legal Basis: Legitimate business interests

7.2 Merchant / Developer Data Processing

We use your personal data to:

8. Advertising

SaylorPay displays advertisements served exclusively by Coinsaylor Solutions' own ad network.

Important Points:

9. When and With Whom We Share Your Information

We only share your information in specific situations—with your consent, to comply with laws, to deliver services, to protect your rights, or to fulfill business obligations—and only with carefully selected parties.

9.1 App User Data Sharing

We may process or share your personal information based on the following legal bases:

We may share your information in the following situations:

  1. With Mobile Network Operators

    • Transaction instructions (recipient number, amount) are transmitted via USSD to your chosen network (MTN, Telecel, AirtelTigo) to execute transactions

  2. With Service Providers

    • Trusted third-party services that help us with:
      • Cloud infrastructure and hosting (e.g., AWS, Google Cloud)
      • Application monitoring and analytics (in anonymized form)
      • Customer support tools
    • All service providers operate under strict confidentiality agreements

  3. Business Transfers

    • We may share or transfer your personal information in connection with any merger, sale of company assets, financing, or acquisition of all or a portion of our business

  4. Third-Party Advertisers

    • We may allow our own advertising network to display ads when you use our product
    • These systems may use cookies or tracking technologies to provide relevant ads

  5. Affiliates

    • We may share your information with our parent company, subsidiaries, joint venture partners, and other companies under common control
    • These parties are required to honor this Privacy Policy

  6. Business Partners

    • We may share information with business partners to offer you certain products, services, or promotions

  7. User-Configured Destinations

    • For optional SMS forwarding, messages are sent only to destinations you explicitly configure

  8. Legal Requirements

    • When required by law, regulation, or legal process

Unless explicitly described here, we do not sell, rent, or trade your personal information to third parties for promotional purposes.

9.2 Merchant / Developer Data Sharing

We may disclose or share your personal data with third parties as reasonably necessary for the purposes set out in this notice.

We share personal data in the following limited circumstances:

  1. With Subsidiaries and Affiliates

    • For processing personal data on our behalf
    • Subject to appropriate confidentiality and security measures

  2. With Third-Party Service Providers

    • Identity verification and fraud prevention services
    • Customer service and support providers
    • Analytics services
    • Payment facilitation by banking and financial service partners, including card networks
    • Communication service providers
    • Information technology services

  3. For Legal Compliance

    • To comply with subpoenas, court orders, summons, or requests from law enforcement agencies and regulatory authorities (which may be outside your country of residence)

  4. To Protect Rights and Prevent Harm

    • To satisfy applicable laws, regulations, legal processes, or governmental requests
    • To detect or prevent fraud, including investigation of potential violations of our Terms of Service
    • To detect, prevent, or address security or technical issues
    • To protect against imminent harm to the rights, property, or safety of SaylorPay, its users, or the public

  5. With Your Consent

    • When you authorize us to share your personal data with third parties
    • The use of your data by authorized third parties is subject to their privacy policies
    • SaylorPay bears no liability for breaches arising from such authorization

  6. Business Transfers

    • If SaylorPay becomes involved in a merger, acquisition, or sale of assets, we may share your personal data with parties involved in the transaction
    • Any entity that acquires our business will continue to process your data in line with this Privacy Policy or a revised version that we will communicate to you

10. Cookies and Other Tracking Technologies

Cookies are small text files stored on your device when you visit a website. They enable the site to remember your actions and preferences over time.

How We Use Cookies:

When you visit our website, we use cookies to:

Important: Cookies do not typically contain information that personally identifies a user. However, personal information we store about you may be linked to information stored in and obtained from cookies.

We may use:

These tools help us:

Your Control: You have the option to control or disable cookies through your browser settings. Note that disabling cookies may affect the functionality and features of our services.

For more information on the specific types of cookies used on our website, please read our Cookie Policy.

11. Data Security and Retention

11.1 App User Data

Security Measures:

We implement a range of organizational and technical security measures designed to protect your personal information, including:

Your Responsibility:

While we take reasonable steps to protect your information, no method of transmission over the internet or electronic storage is 100% secure. We encourage you to:

Retention:

We retain your personal information for as long as necessary to fulfill the purposes outlined in this notice, unless a longer retention period is required or permitted by law.

We keep your personal information only as long as:

Deletion:

When we no longer have a legitimate need to process your personal information, we will either delete, anonymize, or securely store your data and isolate it from any further processing until deletion is possible.

If you have requested data deletion or consent withdrawal, we will securely dispose of your personal information, subject to any legal obligations that require us to retain certain records.

11.2 Merchant / Developer Data

Security Measures:

The security of your personal data is important to SaylorPay. We maintain administrative, technical, and physical controls designed to protect your data against:

Security measures include:

Your Responsibility:

When using your account(s), we urge you to:

Retention:

We will only retain personal data on our servers for as long as is reasonably necessary while we are providing services to you.

If you close your account, your data is stored to the extent necessary to:

Where we retain your personal data, we do so in compliance with limitation periods or retention obligations imposed by applicable law.

12. Your Privacy Rights

12.1 App User Rights

You have rights regarding your personal information, including accessing, correcting, deleting, and restricting how it's used.

Depending on your location and applicable data protection laws, you may have the following rights:

  1. Right to Access

    • Request details about the personal information we hold about you

  2. Right to Correction

    • Request that we update or correct inaccurate or incomplete information

  3. Right to Deletion

    • Request that we delete your personal information, subject to certain legal obligations

  4. Right to Restrict Processing

    • Request that we limit the use of your information under certain circumstances

  5. Right to Data Portability

    • Receive a copy of the personal information we have collected about you in a structured, machine-readable format

  6. Right to Withdraw Consent

    • If we rely on your consent to process your information, you have the right to withdraw it at any time

  7. Right to Object

    • Object to the processing of your personal data where we rely on legitimate interests or for direct marketing purposes

How to Exercise These Rights:

You can exercise these rights by contacting us at: [email protected]

We will respond to your request in accordance with applicable laws. Please note that we may ask you to verify your identity before fulfilling certain requests.

12.2 Merchant / Developer Rights

At SaylorPay, we respect the rights of our Merchants and Developers. Individuals who have personal information held by us are entitled to exercise the following rights under applicable data protection laws:

  1. Right to Request Access

    • Request a copy of your personal information held by SaylorPay

  2. Right to Be Informed

    • Be informed regarding the use of your personal information

  3. Right to Erasure

    • Request that SaylorPay delete or erase your personal data
    • Note: This is a limited right that applies where continued processing has no legal justification
    • Exceptions apply where applicable law requires us to retain historical archives to fulfill regulatory requirements, or where we retain core data to ensure we do not inadvertently contact you if you object to marketing

  4. Right to Request Deletion

    • Request the deletion of your personal information

  5. Right to Data Portability

    • Request the movement of your personal information from SaylorPay to a third party

  6. Right to Revoke Consent

    • Revoke consent previously given

  7. Right to Object

    • Object to direct marketing and request that SaylorPay ceases processing of your information

  8. Right to Institute Civil Proceedings

    • Seek compensation through the courts

  9. Right to Submit a Complaint

    • Lodge a complaint with the Data Protection Commission or relevant authority

How to Exercise These Rights:

Contact us at: [email protected]

13. International Data Transfers

SaylorPay currently operates in Ghana. If we transfer data outside Ghana, we will ensure appropriate safeguards are in place to protect your personal data in accordance with applicable data protection laws.

14. Children's Privacy

SaylorPay services are not intended for individuals under the age of 18. We do not knowingly collect personal information from children. If you believe we have collected information from a child, please contact us immediately at [email protected], and we will take steps to delete such information.

15. Changes to This Privacy Policy

We may update our Privacy Policy from time to time to reflect changes in our practices, technology, legal requirements, or other factors.

We will notify you of any changes by:

You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page.

16. Contact Us

If you have questions, concerns, or requests regarding this Privacy Policy or our data practices, please contact us at:

Coinsaylor Solutions
Email: [email protected]
Website: https://saylorpay.com

17. Regulatory Compliance

SaylorPay is committed to complying with all applicable data protection laws and regulations, including but not limited to:

By using SaylorPay, you acknowledge that you have read, understood, and agree to be bound by this Privacy Policy.