Privacy Policy

Last Updated: April 19, 2025

1. Introduction

SARF Exchange Ltd. ("SARF Exchange", "we", "us", or "our") is committed to protecting your privacy. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you use our website, mobile application, and services (collectively, the "Services").

Please read this Privacy Policy carefully. By accessing or using our Services, you acknowledge that you have read, understood, and agree to be bound by this Privacy Policy. If you do not agree with our policies and practices, please do not use our Services.

2. Information We Collect

We collect several types of information from and about users of our Services:

2.1 Personal Information

Personal information is data that can be used to identify you individually. We may collect the following personal information:

• Contact information (name, email address, phone number, postal address)
• Date of birth
• National identification numbers
• Financial information (bank account details, payment card details)
• Biometric data (for identity verification purposes)
• Photographs (for identity verification purposes)
• Employment information
• Tax identification information

2.2 Non-Personal Information

We also collect non-personal information that does not directly identify you:

• Device information (IP address, browser type, operating system)
• Usage data (pages visited, time spent on pages, links clicked)
• Location data (general geographic location based on IP address)
• Transaction data (trading history, balances, transaction volumes)

3. How We Collect Information

We collect information through various methods:

• Direct collection: Information you provide when registering for an account, completing KYC verification, conducting transactions, or contacting customer support
• Automated collection: Information collected automatically through cookies, web beacons, and other tracking technologies
• Third-party sources: Information from identity verification services, financial institutions, and public databases

4. How We Use Your Information

We use the information we collect for various purposes, including:

• Providing and maintaining our Services
• Processing transactions and managing your account
• Verifying your identity and complying with regulatory requirements
• Detecting and preventing fraud, money laundering, and other illegal activities
• Communicating with you about your account, updates, and promotional offers
• Improving our Services and developing new features
• Analyzing usage patterns and trends
• Resolving disputes and troubleshooting problems
• Enforcing our Terms of Service and other policies

5. Legal Basis for Processing

We process your personal information based on the following legal grounds:

• Performance of a contract: Processing necessary to fulfill our contractual obligations to you
• Legal obligation: Processing necessary to comply with our legal obligations
• Legitimate interests: Processing necessary for our legitimate business interests
• Consent: Processing based on your explicit consent

6. Information Sharing and Disclosure

We may share your information with the following categories of recipients:

6.1 Service Providers

We may share your information with third-party service providers who perform services on our behalf, such as:

• Identity verification services
• Payment processors
• Cloud storage providers
• Customer support services
• Analytics providers

These service providers are contractually obligated to use your information only as directed by us and in accordance with this Privacy Policy.

6.2 Legal Requirements

We may disclose your information if required to do so by law or in response to valid requests by public authorities (e.g., a court or government agency).

6.3 Business Transfers

If we are involved in a merger, acquisition, or sale of all or a portion of our assets, your information may be transferred as part of that transaction.

6.4 With Your Consent

We may share your information with third parties when we have your consent to do so.

7. Data Security

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

• Encryption of sensitive data
• Regular security assessments
• Access controls and authentication mechanisms
• Secure network architecture
• Regular backups

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 its absolute security.

8. Data Retention

We retain your 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. The criteria used to determine our retention periods include:

• The length of time we have an ongoing relationship with you
• Our legal obligations under applicable laws
• The applicable statute of limitations for legal claims

9. Your Rights

Depending on your location, you may have certain rights regarding your personal information:

• Access: The right to request copies of your personal information
• Rectification: The right to request correction of inaccurate information
• Erasure: The right to request deletion of your personal information
• Restriction: The right to request restriction of processing of your personal information
• Data portability: The right to receive your personal information in a structured, commonly used format
• Objection: The right to object to processing of your personal information

To exercise these rights, please contact us using the information provided in the "Contact Us" section below.

10. Cookies and Tracking Technologies

We use cookies and similar tracking technologies to collect information about your browsing activities and to distinguish you from other users of our Services. Cookies are small text files that are stored on your device when you visit a website.

We use the following types of cookies:

• Essential cookies: Necessary for the operation of our Services
• Analytical/performance cookies: Allow us to recognize and count visitors and analyze how users navigate our Services
• Functionality cookies: Used to recognize you when you return to our Services
• Targeting cookies: Record your visit to our Services, the pages you have visited, and the links you have followed

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of our Services may become inaccessible or not function properly.

11. Third-Party Links

Our Services may contain links to third-party websites and services that are not owned or controlled by SARF Exchange. We have no control over, and assume no responsibility for, the content, privacy policies, or practices of any third-party websites or services. We encourage you to review the privacy policies of any third-party websites or services that you visit.

12. Children's Privacy

Our Services are not intended for individuals under the age of 18. We do not knowingly collect personal information from children under 18. If we learn we have collected or received personal information from a child under 18, we will delete that information. If you believe we might have any information from or about a child under 18, please contact us.

13. International Data Transfers

Your information may be transferred to, and processed in, countries other than the country in which you reside. These countries may have data protection laws that are different from the laws of your country.

When we transfer your information to other countries, we will take appropriate safeguards to ensure that your information remains protected in accordance with this Privacy Policy and applicable law.

14. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. We will notify you of any changes by posting the new Privacy Policy on this page and updating the "Last Updated" date at the top of this page.

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.

15. Contact Us

If you have any questions about this Privacy Policy or our privacy practices, please contact us at:

SARF Exchange Ltd.
Independence Avenue
Accra, Ghana
Email: privacy@sarfexchange.com
Phone: +233 (0) 302 123 456