1. Introduction
Smenpay is committed to protecting your privacy. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you use our money transfer and escrow services.

2. Information We Collect
We may collect the following types of information:
- Personal Information: Name, email address, phone number, date of birth, government-issued ID.
- Financial Information: Bank account details, transaction history, payment method.
- Usage Data: Device information, IP address, browser type, access times, and pages viewed.
- KYC Documents: Identity verification documents submitted during registration.

3. How We Use Your Information
We use your information to:
- Facilitate secure money transfers and escrow transactions.
- Verify identity and comply with KYC/AML regulations.
- Provide customer support and resolve disputes.
- Improve our services and user experience.
- Communicate updates, promotions, and legal notices.

4. Sharing Your Information
We do not sell your personal information. We may share data with:
- Payment processors to complete transactions.
- Third-party service providers for analytics, hosting, and support—under strict confidentiality agreements.

5. Data Security
We implement industry-standard security measures including:
- SSL encryption
- Secure server infrastructure
- Access controls and authentication
However, no method of transmission over the internet is 100% secure.

6. Data Retention
We retain your data as long as your account is active or as needed to comply with legal obligations. You may request deletion of your data by contacting us.

7. Your Rights
You have the right to:
- Access and review your personal data.
- Request corrections or deletions.
- Withdraw consent for data processing (where applicable).

8. Cookies and Tracking
We may use cookies to enhance your experience. You can disable cookies in your browser settings, but some features may not function properly.

9. Third-Party Links
Our platform may contain links to third-party websites. We are not responsible for their privacy practices.

10. Changes to This Policy
We may update this Privacy Policy from time to time. Changes will be posted on our website with the updated date.

      KYC and AML Policy
1. Introduction and Purpose
The purpose of this policy is to ensure that Smenpay complies with all relevant anti-money laundering (AML) laws and  regulations. As an escrow provider, we are committed to preventing our platform from being used for the concealment of illicit funds.

2. Customer Identification Program (KYC)
We implement a robust KYC process before any user can initiate or receive a transaction. This is divided into two categories:
A. Individual Accounts
* Full Legal Name
* Date of Birth
* Residential Address (Verified via utility bill or bank statement)
* Government-Issued ID (Passport, Driver’s License, or National ID)

B. Corporate Accounts
* Certificate of Incorporation and Business License.
* Registered Business Address.
* Proof of Authority: Documentation showing the individual opening the account is authorized to act on behalf of the entity.

3. Risk-Based Approach (RBA)
Not all users represent the same level of risk. We apply different levels of scrutiny based on:
* Transaction Volume: Higher amounts trigger deeper due diligence.
* Geographic Risk: Users from  "High-Risk Jurisdictions" may be blocked or require Enhanced Due Diligence (EDD).
* PEP Screening: Checking if a user is a Politically Exposed Person (PEP) or on a Sanctions List.

4. Transaction Monitoring
The Company monitors all escrow transactions for "Red Flags," including:
* Transactions that have no apparent economic or Business purpose.
* Structuring (splitting large payments into smaller amounts to avoid reporting thresholds).
* Funds originating from or destined for high-risk jurisdictions.
* Rapid movement of funds (e.g., depositing and immediately attempting to withdraw without a legitimate transaction).

5. Suspicious Activity Reporting (SAR)
If a transaction is deemed suspicious and cannot be cleared through internal investigation:
* Reporting: A Suspicious Activity Report (SAR) will be filed with the relevant financial authority (e.g., EFCC).
* No Tipping Off: Employees are strictly prohibited from informing a user that they are under investigation or that a SAR has been filed.

6. Record Keeping
In compliance with global standards, Smenpay maintains all records of identification and transactions for a minimum of five (5) years after the business relationship has ended.

7. Training and Compliance Officer
* AML Compliance Officer: A designated individual responsible for overseeing the policy.
* Employee Training: All staff handling transactions must undergo annual AML training to recognize fraud and money laundering patterns.
 

Contact Us
For privacy-related inquiries, contact:  
📧 support@smenpay.com  
📞 +234 8032062796