Privacy Policy
Last updated 2026-08-13
Draft — not legal advice. This document was prepared during development and requires review and completion by a qualified lawyer before launch. Items in square brackets need facts only the operator can supply.
01What we collect
Account details you give us: email address, and a password if you create an account.
Order details: the recipient mobile number, the country and network, the amount, and the outcome.
Payment metadata from our payment processor: card brand, last four digits, issuing country and the result. We never receive or store your full card number.
Technical data: a hashed IP address, a device identifier and a browser family, used to detect fraud.
02How recipient numbers are handled
Recipient mobile numbers are encrypted at rest. They are never written to our logs in full, never sent to analytics, and support staff see only the last four digits.
We also store a one-way keyed hash of the number so we can spot unusual patterns without reading the number itself.
03Why we process it
To deliver the top-up you asked for (performance of a contract).
To prevent fraud and comply with financial-crime obligations (legitimate interests and legal obligation).
To send transactional email about your orders.
With your consent only: analytics that help us see which parts of the service work.
04Who we share it with
Our payment processor, to take payment. Our top-up suppliers, to deliver the credit — they receive the recipient number and amount because there is no other way to deliver it. Our number-lookup provider, to check the number is live.
[LAWYER: list each processor, its location, and the transfer mechanism for international transfers.]
05Your rights
Depending on where you live, you may have the right to access, correct, export or erase your data, and to object to some processing. Contact [PRIVACY CONTACT] to exercise any of these.
[LAWYER: confirm GDPR, UK GDPR, CCPA/CPRA and any other applicable regime are properly addressed, and name the data controller and any representative or DPO.]
06Review required
This document is a working draft prepared during development. It has not been reviewed by a lawyer and must not be published in this form.