Kingspay US - Privacy Notice

1. Introduction

Kinging LLC (Kingspay), ("We", "Us", or "Our") is a Fintech company founded to transform Africa's financial sector by making accessible technology solutions available to all card users. Kingspay provides a payment solution platform that includes the installation of physical Point of Sale devices and checkout points that are integrated into a web-based store.

This Privacy Notice ("Notice") governs your use of our website https://kingspay-gs.com/ (the Website"), as well as any other software, online platform, website, mobile or tablet application, or domains used to provide our services, including but not limited to KingsPay: Point of sale & credit card reader (the "Services"). We provide this Notice because we believe you have a right to know what information we collect, why we collect it, how it is protected and used, and under what circumstances it may be disclosed.

2. Terms of Use

You are required to comply with the provisions of our Terms of Use in relation to the information provided.

3. Your data that we process

Personal data is any information about an individual that can be used to identify that person directly or indirectly. For example, while using the website, we may request personal information from you in order to contact or identify you, and some information may be collected automatically in order for our website to function properly. We also collect personal data from third-party sources or through your use of our services. The data we obtain include:

Full name, email address and account log-in details;
Location - This may include the user’s country;
Billing or shipping address (when you make a transaction);
ATM card number, CVC code and expiration date (when you link your card);
Contact details such as telephone number and postal address;
Personal information such as date of birth, government identifiers associated with you and your organisation such as your social security number, tax number, or Employer Identification Number;
We also receive transaction information of customers of a KingsPay user such as payment method information (credit or debit card number, or bank account information), purchase amount, date of purchase, and payment method. Different payment methods may require the collection of different categories of information.

4. Children’s data

Our services are not directed at persons under the age of thirteen (13), and we request that they do not provide any personal information through our services.

5. Cookies

Cookies are tools that are used to automatically collect information from you when you visit our website. We use cookies, and information about their usage is specified in our Cookie Notice.

6. Lawful bases for processing data

We are required to process your data under at least one of these lawful bases:

Legitimate interest: Processing your data is necessary for our legitimate interests or the legitimate interests of a third party, provided your rights and interests do not outweigh those interests.
Consent: You have given explicit consent for us to process your data for a specific purpose.
Contract: If the data processing is necessary for a contract with us or because we have asked you to take specific steps before entering that contract.
Legal obligation: If the processing of your data is necessary where there is a statutory obligation on us.

7. Purpose of Processing Your Data and the Lawful Bases

Purpose of Processing	Lawful Bases
To administer our business To help us to develop, improve, customise or restructure our services To enforce our terms of service and any terms and conditions of any otder agreements for our services.	Legitimate interest, contract
To send marketing or promotional messages to you messages to you ▪ To install non-necessary cookies on your device.	Consent
To take statistical data and analytics for our use internally To send you service-related messages To analyse Site usage and provide, maintain and improve the content and functionality of the Site.	Legitimate interest
To secure your data and prevent fraud.	Legitimate interest, legal obligation
To manage your account. To communicate with you and for customer support. To address your inquiries, process your registration, and complete your transactions. To enable an easy and effective payment system.	Contract
To inform you of changes to our terms of business or services.	Legal obligation, contract
To fulfill our Know Your Customer (KYC) obligation To interact with regulatory authorities or other public authorities concerning you.	Legal obligation

8. Your Rights as a Data Subject

The law vests you with certain rights as a data subject. They include the right to:

be informed about the personal data we collect from you in the cause of carrying on business. You may make a request for information at most twice within a 12 months period;
access the personal data we hold about you by making a request to that effect;
have your personal data deleted, provided that there are no legal obligations that require us to keep them a little longer;
opt-out from having your personal data sold by directing us not to sell. However, we reiterate that we do not sell your personal data;
not be discriminated against or denied certain service because you have exercised any of your rights;
have your personal data transferred/transmitted to another service provider/data controller.

You may seek to exercise any of the above rights at any time by sending us an email at kingspay@joinkingschat.com.

Where you are not satisfied with our response, you may reach out to California’s Department of Justice to make your complaints.

9. Who we share your data with

The following third party is the entity we share your data with:

Third Parties	Purpose of data sharing
Google Analytics	We use various Google APIs and services for our Website’s operation. Read Google’s Privacy Notice here.
Amazon Web Services	We use Amazon Web Services (AWS) to host applications. Read AWS Privacy Notice here.
Stripe	We use Stripe to process payments. Read Stripe’s Privacy Policy here.
Business Partners	We share personal data we collect from you with business partners such as banks and payment method providers to enable them to provide our services to our users.
Legal and Regulatory Authority	We may disclose your personal data if we believe it is reasonably necessary to comply with a law, regulation, order, subpoena, audit, or to protect the safety of any person, to address fraud, security or technical issues.
Service Providers	We will share your personal data with service providers to enable them to render services to us so that we can provide services to you, including payment processing service providers who conduct data processing on our behalf or for data verification, centralisation or logistics purposes.

Note that if you wish to prevent your device’s operating system from sharing your Personal Data with Kingspay or with the third parties mentioned for profiling purposes, you can do so by setting up your device appropriately – namely, by changing the privacy settings on your device to disable/restrict any advertising tracking features. For more information on this, please see the following links:

9. Who we share your data with

iOS Devices: https://support.apple.com/en-us/HT202074;
Android Devices: https://support.google.com/ads/answer/2662922?hl=en;

10. Retention of your data

The data and any other information we collect from you will be stored for as long as necessary to fulfil the purposes described in this Notice. However, we will retain data in accordance with applicable laws in order to resolve disputes, prevent fraud and abuse, and enforce our legal agreements and policies. Furthermore, once you unsubscribe from our marketing communications, we delete your data for targeted marketing purposes.

Please note that your data may be retained for a longer period, notwithstanding your request to have it removed where there is a legal requirement to do so.

11. How your data is stored and secured

We protect your data using physical, technical, and administrative security measures to reduce the risks of loss, misuse, unauthorised access, disclosure, and alteration. If there is an actual or suspected data breach that could jeopardise your rights and freedoms, we will notify you promptly and use our best efforts to correct the breach.

12. International transfer of data

We are a global business with operations in various countries, and we may transfer your personal data to other countries. Where personal data is to be transferred to a country other than the United States, we will take additional precautions to ensure adequate protection.

Please contact us if you want to learn more about personal data transfers to third countries (including the appropriate transfer mechanisms).

13. Marketing and communications

We only send marketing communications to you with your consent. You may opt-out of our marketing or object to further processing by clicking on the 'unsubscribe' button at the bottom of the page.

14. Complaints

If you are concerned about an alleged breach of data protection law or any other regulation by us, you can contact the Data Protection Officer (DPO) at [ kingspay@joinkingschat.com]. The DPO will investigate your complaint and provide information about how it was handled.

Please be advised that if your complaints are not satisfactorily addressed, you may file a complaint with the relevant data protection authority.

15. Changes to this Notice

We update our privacy notice from time to time. We will notify our users when we make a change, and visitors will know this by checking the last date of update on this page whenever they visit.

16. Contact Us

If you have any questions relating to this Notice, your rights under this Notice, or are not satisfied with how we manage your personal data, kindly reach out to our Data Protection Officer at kingspay@joinkingschat.com

Kingspay Nigeria & UK - Privacy Notice

1. Introduction

Kinging LLC (Kingspay), ("We", "Us", or "Our") is a Fintech company established to transform Africa’s financial sector by providing accessible technology solutions for all card users. Kingspay offers a payment solution platform via the deployment of physical Point of Sale devices and checkout points integrated into a web-based store.

This Privacy Notice (“Notice”) governs your use of our website https://kingspay-gs.com/ (‘the Website”) used to provide our services, including but not limited to KingsPay: Point of sale & credit card reader (referred to as the “Services"). We provide this Notice because you have a right to know what information we collect, why we collect it, how it is protected and used, and the circumstances under which it may be disclosed because your privacy is important to us.

2. Terms of Use

You are required to comply with the provisions of our Terms of Use in relation to the information provided.

3. Your data that we process

Personal data means any information about an individual from which that person can be directly or indirectly identified. For example, while using the website, we may ask you to provide us with certain personal data to contact or identify you and some automatically for our website to function effectively. We also collect personal data through your use of our services or from third-party sources. The data we obtain include:

Full name, email address and account log-in details;
Location - This may include the user’s country;
Billing or shipping address (when you make a transaction);
ATM card number, CVC code and expiration date (when you link your card);
Contact details such as telephone number and postal address;
Personal information such as date of birth, government identifiers associated with you and your organisation such as your social security number, tax number, or Employer Identification Number;
We also receive transaction information of customers of a KingsPay user such as payment method information (credit or debit card number, or bank account information), purchase amount, date of purchase, and payment method. Different payment methods may require the collection of different categories of information.

4. Children’s data

Our services are not directed at persons under the age of thirteen (13) and we request that they do not provide any personal information through our services.

5. Cookies

Cookies are tools used to automatically collect information from you when you visit our website. We use cookies, and information about the usage is specified in our Cookie Notice.

6. Lawful bases for processing data

We are required to process your data under at least one of these lawful bases:

Legitimate interest: Processing your data is necessary for our legitimate interests or the legitimate interests of a third party, provided your rights and interests do not outweigh those interests.
Consent: You have given explicit consent for us to process your data for a specific purpose.
Contract: If the data processing is necessary for a contract with us or because we have asked you to take specific steps before entering that contract.
Legal obligation: If the processing of your data is necessary where there is a statutory obligation on us.

7. Purpose of Processing Your Data and the Lawful Bases

We collect your data:

Purpose of Processing	Lawful Bases
To administer our business To help us to develop, improve, customise or restructure our services To enforce our terms of service and any terms and conditions of any other agreements for our services.	Legitimate interest, contract
To take statistical data and analytics for our use internally To send you service-related messages To analyse Site usage and provide, maintain and improve the content and functionality of the Site.	Legitimate interest
To secure your data and prevent fraud.	Legitimate interest, legal obligation
To manage your account. To communicate with you and for customer support. To address your inquiries, process your registration, and complete your transactions. To enable an easy and effective payment system.	Contract
To inform you whenever there are changes to our terms of business or services.	Legal obligation, contract
To fulfil our Know Your Customer (KYC) obligation To interact with regulatory authorities or other public authorities concerning you.	Legal obligation

8. Your Rights as a Data Subject

The law vests you with certain rights as a data subject. They include the right to:

access personal data we hold about you by requesting a copy of the personal data we hold about you;
rectify such information where you believe it to be inaccurate;
restrict the processing of your data in certain circumstances;
object to the processing of your data where we intend to process such data for marketing purposes;
where feasible, receive all personal data you have provided to us—in a structured, commonly used, and machine-readable format—and transmit the information to another data controller;
request the erasure of your data (also known as the right to be forgotten);
withdraw your consent to the processing of your data; and
lodge a complaint with a relevant authority where you have reason to believe that we have violated the term(s) of this Privacy Notice. (You may complain or seek redress from us within 30 days from when you first detected the alleged violation).

You may seek to exercise any of the above rights at any time by sending us an email at kingspay@joinkingschat.com.

The supervisory authority is the Nigerian Data Protection Bureau (NDPB), and a complaint can be sent via email at info@ndpb.gov.ng.

For our users in the UK, you may read about how to make complaints to the Information Commissioner’s Office here.

9. Who we share your data with

The following third party is the entity we share your data with:

Third Parties	Purpose of data sharing
Google Analytics	We use various Google APIs and services for our Website’s operation. Read Google’s Privacy Notice here.
Amazon Web Services	We use Amazon Web Services (AWS) to host applications. Read AWS Privacy Notice here.
Stripe	We use Stripe to process payments. Read Stripe’s Privacy Policy here.
Business Partners	We share personal data we collect from you with business partners such as banks and payment method providers to enable them to provide our services to our users.
Legal and Regulatory Authority	We may disclose your personal data if we believe it is reasonably necessary to comply with a law, regulation, order, subpoena, audit, or to protect the safety of any person, to address fraud, security or technical issues.
Service Providers	We will share your personal data with service providers to enable them to render services to us to provide services to you, including payment processing services providers or conduct data processing on our behalf, or for data verification, centralisation or logistics purposes.

iOS Devices: https://support.apple.com/en-us/HT202074;
Android Devices: https://support.google.com/ads/answer/2662922?hl=en

10. Retention of your data

The data and any other information we collect from you will be stored for as long as necessary to fulfil the purposes described in this Notice. However, we will also retain data subject to relevant provisions of applicable laws, resolve disputes, prevent fraud and abuse, and enforce our legal agreements and policies. In addition, we delete your data for targeted marketing purposes once you unsubscribe from our marketing communications.

Please note that your data may be retained for a more extended period, notwithstanding your request to remove your data, where there is a legal requirement to do so.

11. How your data is stored and secured

We are very particular about preserving your privacy and protecting your data. We deploy reasonable and appropriate technical and organisational measures to keep your data safe. However, we cannot completely guarantee the security of any information you transmit via our website, as the internet is not an entirely secure place. Nevertheless, we are committed to doing our best to protect you.

We protect your data using physical, technical, and administrative security measures to reduce the risks of loss, misuse, unauthorised access, disclosure and alteration. Where there is an actual or suspected data breach capable of causing harm to your rights and freedoms, we will notify you without undue delay and use our best effort to remedy the breach promptly

12. International transfer of data

To achieve the purposes described in this Notice, we may transfer your data to countries that do not offer adequate protection or are not considered to have good laws by the National Information Technology Development Agency (NITDA). Where personal data is to be transferred to a country outside Nigeria, we shall put supplementary measures to ensure adequate protection.

Our data transfers to countries without adequate protection are subject to the Nigeria Data Protection Regulation (NDPR) conditions. We will, therefore, only transfer Personal Data out of Nigeria on one of the following conditions:

Your consent has been obtained;
The transfer is necessary for the performance of a contract between Us and you or implementation of pre-contractual measures taken at your request;
The transfer is necessary to conclude a contract between Us and the third party in your interest;
The transfer is necessary for reason of public interest;
The transfer is for the establishment, exercise or defence of legal claims; or
The transfer is essential to protect your vital interests or other persons, where the data subject is physically or legally incapable of giving consent.

For transfers outside the United Kingdom, we shall, in addition to the above, ensure to put in place adequate international data transfers agreements, where appropriate.

Please contact us to obtain relevant information regarding your data transfers to third countries (including the appropriate transfer mechanisms).

13. Marketing and communications

We only send marketing communications to you with your consent. You may opt-out of our marketing or object to further processing by clicking on the 'unsubscribe' button at the bottom of the page.

14. Complaints

If you are concerned about an alleged breach of data protection law or any other regulation by us, you can contact the Data Protection Officer (DPO) at kingspay@joinkingschat.com. The DPO will investigate your complaint and provide information about how your complaint is handled.

Please be informed that you may complain to the relevant data protection authority if your complaints are not satisfactorily addressed.

15. Changes to this Notice

We update our privacy notice from time to time. We will notify our users when we make a change, and visitors will know this by checking the last date of update on this page whenever they visit.