Privacy Policy

At Spearheadpay, we are committed to protecting your privacy and ensuring the security of your personal information. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you use our services.

We understand that trust is essential when it comes to financial services, and we take our responsibility to protect your data seriously. This policy applies to all users of our website, mobile applications, and other services (collectively, the "Services").

2.1 Personal Information

We collect the following types of personal information:

• Identity Information: Full name, date of birth, nationality, government-issued ID numbers
• Contact Information: Email address, phone number, residential address
• Financial Information: Bank account details, payment card information, transaction history
• Verification Documents: Passport, driver's license, utility bills, bank statements
• Employment Information: Occupation, employer name, source of funds

2.2 Automatically Collected Information

• Device Information: IP address, browser type, device type, operating system
• Usage Data: Pages visited, features used, time spent on our Services
• Location Data: Geographic location based on IP address or device settings
• Cookies and Tracking: We use cookies and similar technologies to enhance user experience

2.3 Information from Third Parties

We may receive information about you from third-party sources, including:

• Identity verification services
• Credit reference agencies
• Fraud prevention services
• Payment processors
• Partner financial institutions

We use your personal information for the following purposes:

3.1 Service Provision

• Process and complete money transfer transactions
• Manage your account and provide customer support
• Send transaction confirmations and status updates
• Verify your identity and authenticate transactions

3.2 Legal and Regulatory Compliance

• Comply with anti-money laundering (AML) and counter-terrorist financing (CTF) regulations
• Fulfill know-your-customer (KYC) requirements
• Report suspicious activities to relevant authorities
• Respond to legal requests and prevent fraud

3.3 Service Improvement

• Analyze usage patterns to improve our Services
• Develop new features and functionality
• Conduct research and analytics
• Test and troubleshoot technical issues

3.4 Marketing and Communications

• Send promotional offers and updates about our Services (with your consent)
• Provide personalized recommendations
• Conduct customer surveys and feedback requests

We do not sell your personal information to third parties. However, we may share your information with:

4.1 Service Providers

• Payment processors and banking partners
• Identity verification services
• Cloud storage and hosting providers
• Customer support platforms
• Analytics and marketing service providers

4.2 Legal and Regulatory Authorities

We may disclose your information to law enforcement, regulators, courts, and other authorities when required by law or to protect our rights and the safety of our users.

4.3 Business Transfers

In the event of a merger, acquisition, or sale of assets, your information may be transferred to the acquiring entity. We will notify you of any such change in ownership or control of your personal information.

4.4 With Your Consent

We may share your information with third parties when you have given us explicit consent to do so.

We implement industry-standard security measures to protect your personal information, including:

• Encryption of data in transit and at rest using SSL/TLS protocols
• Multi-factor authentication for account access
• Regular security audits and penetration testing
• Access controls and employee training on data protection
• Secure data centers with physical and electronic safeguards
• Incident response and breach notification procedures

While we strive to protect your information, no method of transmission over the internet or electronic storage is 100% secure. We cannot guarantee absolute security, but we continuously work to improve our security measures.

We retain your personal information for as long as necessary to:

• Provide our Services to you
• Comply with legal and regulatory obligations (typically 5-7 years for financial records)
• Resolve disputes and enforce our agreements
• Prevent fraud and abuse

When your information is no longer needed, we securely delete or anonymize it in accordance with our data retention policies and applicable laws.

Depending on your jurisdiction, you may have the following rights regarding your personal information:

7.1 Access and Portability

You have the right to request a copy of the personal information we hold about you and to receive it in a structured, commonly used format.

7.2 Correction and Update

You can update your account information at any time through your account settings or by contacting our support team.

7.3 Deletion

You may request deletion of your personal information, subject to legal and regulatory retention requirements.

7.4 Marketing Opt-Out

You can opt out of marketing communications at any time by clicking the "unsubscribe" link in our emails or by updating your preferences in your account settings.

7.5 Cookie Preferences

You can manage cookie preferences through your browser settings. However, disabling certain cookies may affect the functionality of our Services.

Your information may be transferred to and processed in countries other than your country of residence. These countries may have different data protection laws than your jurisdiction.

When we transfer your information internationally, we ensure appropriate safeguards are in place, such as:

• Standard contractual clauses approved by relevant authorities
• Data processing agreements with third parties
• Compliance with Privacy Shield or similar frameworks where applicable

Our Services are not intended for individuals under the age of 18. We do not knowingly collect personal information from children. If we become aware that we have collected information from a child without parental consent, we will take steps to delete that information.

Our Services may contain links to third-party websites or services. We are not responsible for the privacy practices of these third parties. We encourage you to review their privacy policies before providing any personal information.

We may update this Privacy Policy from time to time to reflect changes in our practices or legal requirements. We will notify you of material changes by posting the updated policy on our website and updating the "Last updated" date. We encourage you to review this policy periodically.

If you have any questions about this Privacy Policy or how we handle your personal information, please contact our Data Protection Officer:

You also have the right to lodge a complaint with your local data protection authority if you believe we have not handled your personal information appropriately.

13.1 European Union (GDPR)

If you are located in the EU, you have additional rights under the General Data Protection Regulation (GDPR), including the right to object to processing, the right to restriction of processing, and the right to lodge a complaint with a supervisory authority.

13.2 California (CCPA)

If you are a California resident, you have rights under the California Consumer Privacy Act (CCPA), including the right to know what personal information is collected, the right to delete personal information, and the right to opt-out of the sale of personal information (note: we do not sell personal information).

13.3 Other Jurisdictions

We comply with applicable data protection laws in all jurisdictions where we operate. If you have specific questions about your rights in your jurisdiction, please contact us.