Privacy policy
Last updated: April 20, 2026 · Effective: April 20, 2026
This Privacy Policy explains how ZootPay ("ZootPay", "we", "us") collects, uses, shares, and protects personal data when you use the website zootpay.net, the ZootPay mobile app for Android and iOS, and any related APIs (together, the "Service"). It applies to users worldwide, with additional notes for residents of Haiti, the European Economic Area, the United Kingdom, and the United States.
ZootPay lets you buy, sell, send, receive, and hold cryptocurrencies using Haitian mobile money (MonCash today, NatCash when available) and, for withdrawals, on-chain blockchain transfers. By using the Service you agree to the practices described below and in our Terms of Service and AML/KYC Policy.
1. Who operates the Service
The Service is operated by ZootPay, an unincorporated venture based in Port-au-Prince, Haiti, pending formal incorporation as [LEGAL_ENTITY_FULL_NAME]. Until incorporation is complete, the data controller responsible for your personal data is Eddyson Beauville, reachable at the contact details in Section 14.
2. Data we collect
We collect the following categories of personal data:
a. Account & identity data
- Phone number (used as your primary login identifier)
- Display name, email address (optional)
- Preferred language (Haitian Creole, French, English, or Spanish)
- For users whose activity exceeds the no-KYC threshold: full legal name, date of birth, government-issued ID number and photograph, a live selfie used for identity verification, and residential address. See Section 5 below.
b. Transaction & financial data
- MonCash / NatCash transaction identifiers, mobile-money phone number, amounts, timestamps, and success/failure status
- Crypto asset, quantity, USD value, per-user deposit addresses we generate on your behalf, and external addresses you withdraw to or send to other ZootPay users
- On-chain transaction hashes, network fees, exchange-rate quotes, and the spread we charged
c. Device & technical data
- IP address, approximate geolocation (city / country level derived from IP), browser or app version, operating system, device model, Capacitor / WebView version
- Firebase Cloud Messaging (FCM) registration token used to deliver push notifications to the ZootPay mobile app
- Session cookies, a secure authentication cookie, a locale-preference cookie, and locally-stored biometric-unlock preferences on your device
d. Support & communications data
- Messages you send to support@zootpay.net, compliance@zootpay.net, or legal@zootpay.net
- SMS one-time passwords we send to verify your phone number, delivered via Twilio
e. We do NOT collect
- We never ask for your private keys, seed phrases, or wallet recovery phrases.
- We do not collect sensitive categories such as health, political opinions, religious beliefs, sexual orientation, genetic or biometric data (beyond an identity selfie, only where KYC is triggered).
- We do not sell personal data to advertisers or data brokers.
3. Why we collect it (legal bases)
| Purpose | Legal basis |
|---|---|
| Providing the Service you asked for (creating your account, processing buys/sells/transfers) | Performance of a contract with you |
| Complying with anti-money-laundering, counter-terrorism-financing, and sanctions laws | Legal obligation |
| Detecting and preventing fraud, abuse, and unauthorized access | Legitimate interest |
| Sending transactional notifications (deposit credited, order filled, P2P received) | Performance of a contract |
| Sending product updates and marketing emails (if you opt in) | Your consent; you can withdraw at any time |
| Operating and improving the Service (analytics, crash reports) | Legitimate interest |
4. Third-party processors we share data with
We use the following third-party service providers. Each one receives only the minimum data it needs to perform its function, under a data processing agreement.
| Provider | What they do | Data shared |
|---|---|---|
| Digicel MonCash (Haiti) | Mobile-money deposits and payouts | Your mobile-money phone number, transaction amount, reference ID |
| Unitransfer NatCash (Haiti) — when enabled | Alternative mobile-money rails | Same as above |
| Twilio Inc. (USA) | SMS one-time passwords and verification codes | Your phone number and the code we send |
| Sumsub / Sum & Substance Ltd. (UK) — when KYC is triggered | Identity document + selfie verification | Your ID images, selfie, name, date of birth, address |
| CoinGecko (Singapore) | Public crypto-price data used for quotes | Nothing personal. We only query prices. |
| Jupiter Aggregator (Solana), 1inch (EVM), major exchanges | Executing your buy/sell orders on-chain | The wallet addresses and amounts involved — not your identity |
| Google Firebase Cloud Messaging (USA) | Push notifications to the mobile app | FCM device token and notification payload |
| Vercel Inc. (USA) | Hosting the web app and APIs | All request data (in transit, processed ephemerally) |
| Neon Inc. (USA) | Managed PostgreSQL database | Your account and transaction records at rest |
| Law-enforcement and regulators | Only when compelled by a valid subpoena, court order, or where required by Haitian AML/CFT law | Only what is legally required |
We do not share your personal data with advertising networks. We do not use behavioural-advertising cookies.
5. KYC & identity verification
ZootPay applies a tiered Know-Your-Customer model. See our AML/KYC Policy for full detail. In short:
- Tier 0 — below $500/day: phone verification only. No ID required.
- Tier 1 — up to $2,500/day: basic KYC — government ID photo and a live selfie, processed by Sumsub.
- Tier 2 — above $2,500/day: enhanced KYC — proof of address, source-of-funds declaration, and our review.
You can continue using ZootPay at any tier without upgrading. If you attempt a transaction that exceeds your tier, we will ask you to complete the next tier before processing it. Any data you submit for KYC is retained as required by Haitian AML law (currently 5 years after your last activity) and then deleted.
6. How long we keep your data
- Account data: for as long as your account is active, plus up to 12 months after closure for dispute resolution.
- Transaction records: at least 5 years after the transaction, as required by AML/CFT record-keeping obligations.
- KYC documents: 5 years after your last activity, then permanent deletion.
- Support emails and SMS logs: up to 24 months.
- Push-notification tokens: until you uninstall the app or revoke permission; invalid tokens are purged automatically.
7. Your rights
Regardless of where you live, you have the right to:
- Access — request a copy of the personal data we hold about you
- Correct — fix anything that is inaccurate
- Delete — request deletion of your account and associated data, subject to the AML retention obligations above
- Port — receive your data in a machine-readable format
- Restrict or object — ask us to pause processing that relies on legitimate interest
- Withdraw consent for marketing at any time — use the unsubscribe link in any email
- Lodge a complaint with your local data-protection regulator
To exercise any of these rights, email privacy@zootpay.net. We will respond within 30 days. If we cannot comply (for example because we are required to keep a record by Haitian law), we will tell you why.
8. How we protect your data
- TLS 1.2+ in transit for every request
- Per-user encryption of derived private keys using AES-256 with a master key held in Vercel's encrypted environment variables
- Password-less login via SMS one-time passwords — no password to leak
- Optional biometric unlock on the mobile app for an additional local layer
- Principle of least privilege for employee access
- Hot-wallet reserves monitored for under-collateralisation via an operational dashboard
No system is perfectly secure. If a data breach affecting your personal data occurs, we will notify you and the relevant authorities without undue delay, in accordance with applicable law.
9. Children
The Service is not intended for anyone under 18 years of age. We do not knowingly collect data from children. If we learn we have, we will delete it.
10. International transfers
Our infrastructure is hosted in the United States (Vercel, Neon, Firebase) and Singapore (CoinGecko). If you are outside those jurisdictions, your data will be transferred to and processed there. Where required, we rely on Standard Contractual Clauses or equivalent safeguards.
11. Cookies & similar technologies
We use a small, strictly-necessary set of cookies and local storage:
zp_session— secure, httpOnly authentication cookiezp_locale— remembers your language preferencezp_biometric(localStorage) — remembers whether you enabled biometric unlock on the mobile app
We do not use advertising or analytics cookies. You can clear cookies at any time in your browser settings; clearing them will sign you out.
12. Mobile-app permissions
- Notifications — to deliver transaction alerts. Can be revoked in Android / iOS settings.
- Biometrics — only if you enable the in-app biometric-unlock feature. Biometric matching happens on-device; we never see your fingerprint or face data.
- Camera — only when you are completing KYC, to capture your ID document and selfie.
- Clipboard — only when you tap "Copy" next to a wallet address.
13. Changes to this policy
We may update this policy to reflect changes in the Service, the law, or our practices. When we make material changes, we will notify active users by email, in-app notice, or push notification at least 14 days before the change takes effect, unless a shorter period is required by law. The current version is always available at zootpay.net/legal/privacy.
14. Contact
ZootPay
Port-au-Prince, Haiti
Email (privacy): privacy@zootpay.net
Email (general): support@zootpay.net
Email (legal process): legal@zootpay.net