HoyaPay Privacy Policy

Effective Date: December 1, 2025

HoyaPay (hereinafter referred to as “the Platform,” “HoyaPay,” “we,” or “us”) values and respects your personal data and privacy. This Privacy Policy explains how we collect, use, share, protect, and retain your information when you use the HoyaPay App, our e-wallet services, card services, the H Credits / USDⒽ rewards system, and other related features.

By using the Platform, you acknowledge that you have read, understood, and agreed to all of the terms of this Privacy Policy.

1. Information We Collect

1.1 Information You Provide to Us

We only collect information necessary for providing our services, complying with legal requirements, and improving your user experience. The types of information we may collect include:

  • Name and date of birth

  • Mobile phone number and email address

  • Identity verification (KYC) data (such as passport, national ID, selfie photos, etc.)

  • Residential address or billing address

  • Payment information (excluding full credit card numbers; limited to transaction details)

  • Customer support communications and inquiries

1.2 Information Collected Automatically When You Use the Services

  • Device information (such as model, operating system, language, IP address, device identifiers)

  • Usage data (such as clicks, interaction times, and feature usage)

  • Log data (such as login times, error logs, crash reports)

  • Transaction records (such as top-ups, payments, card transactions, rewards usage, etc.)

1.3 Location Information (If Used)

  • We may collect approximate location information (not precise GPS) only when necessary.

  • Purpose: fraud prevention, regulatory compliance, or enabling specific services.

1.4 User-Generated Content (UGC)

If you enter notes, names, images, customer support messages, or other content on the Platform, such content may be treated as user-generated content that you voluntarily provide.

2. How We Use Your Information

2.1 To Provide Our Services

We use your information to:

  • Create and maintain your account

  • Complete identity verification (KYC)

  • Process transactions, payments, top-ups, and card-related services

  • Calculate, grant, and manage rewards (H Credits / USDⒽ)

2.2 For Security and Legal Compliance

We use your information to:

  • Prevent fraud, abuse, or illegal activities

  • Conduct risk management and system security monitoring

  • Comply with applicable AML/CFT (Anti-Money Laundering / Counter-Terrorist Financing) regulations

2.3 To Improve Our Services

We use your information to:

  • Optimize app content and user interface

  • Analyze technical issues and troubleshoot errors

  • Perform statistical and operational analyses (without identifying you personally where possible)

2.4 Based on Your Consent

We will use your information for push notifications, promotional offers, or marketing activities only if you have granted us the necessary permissions.

3.How We Share Your Information

HoyaPay does not sell any user data. We only share your information with third parties where necessary, including:

3.1 KYC / Identity Verification Providers

Used to verify your identity and reduce risk.

3.2 Blockchain Networks (When Using On-Chain Services)

Transaction information may be publicly recorded on a blockchain, but this does not include your personal identifying information.

3.3 Financial and Payment Partners

Used for card transactions, top-ups, and payment processing.

3.4 Technical Service Providers

Such as data storage, analytics, push notification services, and cloud service providers.

3.5 Legal Requirements We may disclose information where required to do so by a court order, law enforcement request, or applicable laws and regulations.

4. Third-Party Services

The Platform may contain links to, or integrate with, third-party services (for example: payment APIs, identity verification APIs, analytics tools). The use of your data by such third parties is governed by their own privacy policies, and we are not responsible for their privacy practices.

5. Data Retention

We retain your information in accordance with the following principles:

If your account is deleted, certain information may still be retained for a legally mandated period

  • For as long as necessary to provide the services to you

  • For the retention period required by law (for example, financial transaction records may need to be retained for 5 years)

  • If your account is deleted, certain information may still be retained for a legally mandated period

After the applicable retention period expires, we will delete or anonymize your data.

6. Data Security

We implement industry-standard security measures to protect your data, including but not limited to:

Strict internal access controls

  • SSL / TLS encryption for data transmission

  • Bank-grade encryption for data storage

  • Firewalls and network segregation

  • Risk monitoring and abnormal activity detection However, due to the inherent nature of online services, no system can be guaranteed to be completely secure. While we strive to protect your data, we cannot guarantee absolute security.

7. Your Rights

You have the right to:

  • Access the information we hold about you

  • Request corrections to inaccurate or incomplete data

  • Object to the use of your data for marketing purposes

  • Manage your push notification and consent settings

  • Request deletion of your account (subject to legal retention requirements)

The method for exercising these rights will follow the procedures provided in the Platform or through our customer support channels.

8. Account Deletion

You may submit a request to delete your account at any time. After deletion:

  • Your account will no longer be usable

  • Data not required by law will be deleted

  • Data that must be retained under applicable laws and regulations will be retained as required

9. Children’s Privacy

The Platform is intended only for users who are 18 years of age or older. We do not knowingly collect information from minors. If we become aware that a minor is using our services, we will promptly delete or deactivate the related account.

10. Disclaimer of Relationship with Apple / Google

The virtual assets, rewards, points, payment services, and promotional activities provided by the Platform are not in any way associated with Apple Inc. or Google LLC.

Apple and Google do not:

Assume any legal responsibilities related to these services

  • Participate in any transactions

  • Issue or manage points or rewards

  • Provide card services If you make in-app purchases through the App Store, the related billing and refund processes are governed by Apple’s terms and handled by Apple.

11. Changes to This Policy

We may update this Privacy Policy from time to time due to legal, technical, or operational needs. If there are material changes, we will notify you via an in-app notice or other appropriate means.

12. ontact Us

If you have any questions about this Privacy Policy, please contact us at:

HoyaPay Customer Support Team Email: support@hoyapay.com

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