Privacy Policy

Effective Date: [DATE — TODO: set before launch]

This Privacy Policy describes how Smiley Pay Limited collects, uses, stores, discloses, protects, and deletes personal information when you use our Service.

1. Information We Collect

Personal: Name, email, phone, address, account credentials.

Biometric: Facial photographs, live scans, geometry, templates, embeddings, authentication logs. Collected only with consent; never sold.

Transaction: Merchant name, amount, timestamp, status. We do not store card numbers.

Device/Usage: Device identifiers, IP, session info, authentication attempts.

2. How We Use Information

Identity verification, authentication, fraud prevention, customer support, improving accuracy, legal compliance. We do not use biometric information for advertising.

3. Sharing

We may share with payment processors, cloud providers, fraud prevention partners, and when legally required. We do not sell personal information.

4. Retention & Security

Retained only as long as necessary. Protected by encryption, access controls, monitoring. No system is perfectly secure.

5. Your Rights

Depending on applicable law: access, correction, deletion, portability, withdrawal of biometric consent, account closure.

6. Contact

Smiley Pay Limited
Address: [ADDRESS — TODO]
Email: privacy@smileylimited.com
Website: smileylimited.com