Privacy Policy

Introduction

Zarrow (“we,” “our,” or “us”) is committed to protecting your privacy. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you use our peer-to-peer payment mobile application and services (collectively, the “Service”).

This Privacy Policy is designed to comply with the Protection of Personal Information Act, 2013 (POPIA) and other applicable South African laws and regulations.

Please read this Privacy Policy carefully. By using Zarrow, you agree to the collection and use of information in accordance with this policy. If you do not agree with our policies and practices, please do not use our Service.

Information We Collect

Personal Information You Provide

When you create a Zarrow account and use our Service, we collect the following information:

Account Information:

• Full name
• Email address
• Mobile phone number
• Date of birth
• South African ID number or passport number
• Physical address
• Profile photo (optional)
• Zarrow tag name

Financial Information:

• Bank account details (account number, bank name, branch code)
• Payment card information (processed securely through our payment processors)
• Transaction history
• Beneficiary information

Transaction Information:

• Payment amounts
• Transaction notes and descriptions
• Recipient and sender information
• Split payment participant details
• Payment request details
• QR code scan data
• Date and time of transactions

Investor and Demo Requests:

• Name and contact information
• Investment interests and financial capacity (for investor inquiries)
• Business or organization details (for demo requests)

Information Collected Automatically

When you use Zarrow, we automatically collect certain information:

Device Information:

• Device type and model
• Operating system and version
• Unique device identifiers
• Mobile network information
• IP address

Usage Information:

• App features accessed
• Time and duration of app usage
• QR code scanning activity
• Search queries within the app
• Interaction with notifications

Location Information:

• Approximate location based on IP address
• Precise location (only with your permission) for fraud prevention and security purposes

Information from Third Parties

We may receive information about you from:

• Identity verification services
• Fraud prevention and security service providers
• Banks and financial institutions
• Credit bureaus (where permitted by law)
• Public databases and records

How We Use Your Information

We use your personal information for the following purposes:

Service Provision

• Create and manage your Zarrow account
• Process peer-to-peer payments, payment requests, and split payments
• Enable QR code payment features
• Maintain beneficiary lists
• Send transaction confirmations and receipts
• Provide customer support

Security and Fraud Prevention

• Verify your identity in compliance with FICA (Financial Intelligence Centre Act)
• Detect and prevent fraud, money laundering, and unauthorized transactions
• Monitor and analyze security threats
• Protect against illegal activities

Legal and Regulatory Compliance

• Comply with POPIA, FICA, and other applicable South African laws
• Respond to legal requests and prevent harm
• Enforce our Terms of Service
• Maintain records as required by financial regulations

Service Improvement

• Analyze usage patterns to improve app functionality
• Develop new features and services
• Conduct research and analytics
• Test and optimize app performance

Communications

• Send transaction notifications and alerts
• Provide customer service updates
• Send important security and policy updates
• Process investor inquiries and demo requests
• Send promotional communications (with your consent, which you can withdraw at any time)

How We Share Your Information

We may share your personal information in the following circumstances:

Transaction Counterparties

When you send money, request payment, or participate in split payments, we share necessary information (such as your name and Zarrow tag) with other users involved in the transaction.

Service Providers

We share information with trusted third-party service providers who assist us in operating our Service:

• Payment processors and banks
• Identity verification services
• Cloud hosting providers
• Customer support platforms
• Analytics and data processing services
• Fraud detection and prevention services

These service providers are contractually obligated to protect your information and use it only for the purposes we specify.

Legal and Regulatory Authorities

We may disclose your information when required by law or to:

• Comply with legal obligations, court orders, or government requests
• Respond to requests from the South African Reserve Bank, FICA Centre, or other regulatory bodies
• Enforce our Terms of Service
• Protect the rights, property, or safety of Zarrow, our users, or the public
• Detect and prevent fraud or security issues

Business Transfers

If Zarrow is involved in a merger, acquisition, sale of assets, or bankruptcy, your information may be transferred as part of that transaction. We will notify you of any such change and any choices you may have.

With Your Consent

We may share your information for other purposes with your explicit consent.

Aggregated and De-identified Information

We may share aggregated or de-identified information that cannot reasonably be used to identify you for research, marketing, or other business purposes.

Data Security

We implement appropriate technical and organizational security measures to protect your personal information against unauthorized access, alteration, disclosure, or destruction. These measures include:

• End-to-end encryption for sensitive financial data
• Secure Socket Layer (SSL) technology for data transmission
• Multi-factor authentication options
• Regular security audits and vulnerability assessments
• Employee training on data protection and privacy
• Secure data centers with physical and digital access controls
• Firewall protection and intrusion detection systems

However, no method of transmission over the internet or electronic storage is 100% secure. While we strive to use commercially acceptable means to protect your information, we cannot guarantee absolute security.

Your Rights Under POPIA

As a South African data subject, you have the following rights regarding your personal information:

Right to Access

You have the right to request access to the personal information we hold about you. You can access most of your information directly through the Zarrow app.

Right to Correction

You have the right to request correction of inaccurate or incomplete personal information. You can update most information directly in the app settings.

Right to Deletion

You have the right to request deletion of your personal information, subject to certain legal exceptions (such as records we must retain for regulatory compliance).

Right to Object

You have the right to object to the processing of your personal information in certain circumstances, including for direct marketing purposes.

Right to Restrict Processing

You have the right to request restriction of processing your personal information in certain situations.

Right to Data Portability

You have the right to request a copy of your personal information in a structured, commonly used, and machine-readable format.

Right to Lodge a Complaint

You have the right to lodge a complaint with the Information Regulator of South Africa if you believe we have not handled your personal information appropriately.

To exercise any of these rights, please contact us using the information provided in the “Contact Us” section below.

Data Retention

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

Active Accounts: While your account is active, we retain your information to provide our services.

Closed Accounts: After you close your account, we retain certain information as required by:

• FICA regulations (minimum 5 years after account closure)
• Tax laws and regulations
• Other legal and regulatory requirements

Transaction Records: Financial transaction records are retained for a minimum of 5 years as required by South African financial regulations.

After the required retention period, we will securely delete or anonymize your personal information.

Children's Privacy

Zarrow is not intended for use by individuals under the age of 18. We do not knowingly collect personal information from children under 18. If you are a parent or guardian and believe your child has provided us with personal information, please contact us immediately, and we will delete such information from our systems.

International Data Transfers

Your information is primarily stored and processed in South Africa. If we transfer your information outside of South Africa, we will ensure appropriate safeguards are in place to protect your information in accordance with POPIA requirements.

Third-Party Services

Our Service may contain links to third-party websites, services, or applications that are not operated by us. We are not responsible for the privacy practices of these third parties. We encourage you to review the privacy policies of any third-party services you access through our Service.

Cookies and Tracking Technologies

Zarrow uses cookies and similar tracking technologies to enhance your experience. You can control cookie settings through your device settings, but disabling certain cookies may limit your ability to use some features of our Service.

Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, technology, legal requirements, or other factors. We will notify you of any material changes by:

• Posting the new Privacy Policy in the app
• Sending you an email notification
• Displaying an in-app notification

Your continued use of Zarrow after changes become effective constitutes your acceptance of the revised Privacy Policy.