Privacy Policy

Last Updated: October 6, 2025

This Privacy Policy describes how Ognimohub ("we," "us," or "our") collects, uses, processes, and discloses your information in connection with your access to and use of the Ognimohub platform, including our website, mobile applications, and related services (collectively, the "Services"). We are committed to protecting your privacy and handling your data in an open and transparent manner. This policy outlines our practices in compliance with applicable data protection laws and regulations, including but not limited to the General Data Protection Regulation (GDPR), the California Consumer Privacy Act (CCPA), and other relevant international and regional privacy frameworks.

We encourage you to read this Privacy Policy carefully to understand our views and practices regarding your personal data and how we will treat it. By accessing or using our Services, you acknowledge that you have read, understood, and agree to the terms of this Privacy Policy. If you do not agree with this Privacy Policy, please do not use our Services.

1. Information We Collect

We collect various types of information to provide and improve our Services, including information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household ("Personal Data").

1.1 Information You Provide to Us

When you register for an account, use our Services, or communicate with us, you may provide us with the following types of Personal Data:

• Contact Information: Your full name, email address, postal address, phone number, and other similar contact data .
• Identity Verification Information: Date of birth, nationality, government-issued identification numbers (e.g., passport number, national ID number, driver's license number), and images of your identification documents. This information is collected to comply with Know Your Customer (KYC) and Anti-Money Laundering (AML) regulations.
• Financial Information: Bank account details, payment card numbers, transaction history, and other financial details necessary for processing payments and providing our financial services.
• Transaction Information: Details about the transactions you conduct through our Services, including the amount, type of transaction (e.g., send money, mobile recharge, bill payment), recipient details, and timestamps.
• Profile Information: Username, password, profile picture, and other information you add to your Ognimohub profile.
• Communications: Records of your communications with us, including customer support inquiries, feedback, and survey responses.
• Marketing Preferences: Your preferences for receiving marketing communications from us.

1.2 Information We Collect Automatically

When you access or use our Services, we automatically collect certain information about your device and usage patterns:

• Device Information: Device type, operating system, unique device identifiers, mobile network information, and browser type.
• Log Data: Server logs may include your IP address, access dates and times, features or pages viewed, app crashes, and other system activity.
• Location Information: Depending on your device settings and permissions, we may collect precise or approximate location information via GPS, Wi-Fi, or cellular triangulation. This is used for fraud prevention, security, and to offer location-based services.
• Usage Information: Information about how you interact with our Services, such as the features you use, the time spent on certain pages, and your navigation paths.
• Cookies and Similar Technologies: We use cookies, web beacons, and other tracking technologies to collect information about your browsing activities, remember your preferences, and personalize your experience. For more details, please refer to our Cookie Policy.

1.3 Information We Collect from Third Parties

We may receive information about you from third parties, including:

• Financial Institutions and Payment Service Providers (PSPs): When you link your bank account or use a payment card through our Services, we receive information from these entities to facilitate transactions and verify your identity.
• Identity Verification Services: We use third-party services to verify your identity and comply with regulatory requirements, which may provide us with additional information about you.
• Credit Bureaus and Fraud Prevention Agencies: To assess creditworthiness (for microfinance services) and prevent fraud, we may receive information from these agencies.
• Publicly Available Sources: We may collect information from publicly accessible databases to verify your identity or for compliance purposes.
• Affiliate and Referral Partners: If you participate in our affiliate or referral programs, we may receive information about your referrals and earnings from our partners.

2. How We Use Your Information

We use the information we collect for various purposes, primarily to provide, maintain, protect, and improve our Services, and to develop new ones. Our legal bases for processing your Personal Data include:

• Performance of a Contract: To fulfill our contractual obligations to you, such as processing transactions, providing customer support, and managing your account.
• Legal Obligation: To comply with legal and regulatory requirements, including KYC, AML, fraud prevention, and tax obligations.
• Legitimate Interests: For our legitimate business interests, provided that these interests do not override your fundamental rights and freedoms. This includes improving our Services, marketing, security, and analytics.
• Consent: Where you have given us explicit consent to process your Personal Data for a specific purpose .

Specifically, we use your information for the following purposes:

2.1 Providing and Managing Our Services

• Account Creation and Management: To set up and maintain your Ognimohub account, verify your identity, and manage your profile.
• Transaction Processing: To facilitate and process all types of transactions, including send money, mobile recharge, bank transfers, payment collection, and utility bill payments.
• Customer Support: To provide customer service, respond to your inquiries, and resolve issues related to your account or transactions.
• Service Delivery: To deliver the specific services you request, such as issuing virtual cards, providing microfinance access, and managing payment links.
• Gateway Swaps: To enable seamless gateway swaps between different payment systems as per your instructions.

2.2 Security and Fraud Prevention

• Identity Verification: To verify your identity and prevent unauthorized access to your account.
• Fraud Detection and Prevention: To monitor for and prevent fraudulent activities, money laundering, and other illegal activities.
• Security Enhancements: To enhance the security of our Services, including implementing and maintaining technical and organizational security measures.

2.3 Compliance and Legal Obligations

• Regulatory Compliance: To comply with all applicable laws, regulations, and industry standards, including KYC, AML, PCI DSS, and data protection laws.
• Legal Proceedings: To respond to legal requests, court orders, and enforce our terms and conditions.

2.4 Improving and Personalizing Our Services

• Analytics and Research: To analyze usage patterns, conduct research, and gather insights to improve the functionality, performance, and user experience of our Services.
• Personalization: To personalize your experience on our platform, such as recommending relevant services or features.
• Product Development: To develop new features, products, and services based on user needs and market trends.

2.5 Marketing and Communications

• Marketing Communications: To send you promotional materials, newsletters, and updates about our Services, special offers, and new features, where you have consented to receive such communications.
• Operational Communications: To send you important service-related notices, such as transaction confirmations, security alerts, and updates to our terms or policies.
• Referral and Affiliate Programs: To manage and track your participation in our referral and affiliate programs and process associated earnings.

3. How We Share Your Information

We may share your Personal Data with third parties in the following circumstances:

3.1 With Your Consent

We may share your information with third parties when you give us explicit consent to do so.

3.2 With Service Providers

We engage trusted third-party service providers to perform functions and provide services on our behalf. These service providers include:

• Payment Service Providers (PSPs) and Financial Institutions: To process transactions, facilitate bank transfers, and manage payment gateways.
• Identity Verification and Fraud Prevention Services: To verify your identity and detect fraudulent activities.
• Cloud Hosting Providers: To store and process our data securely (e.g., AWS, Google Cloud, Microsoft Azure).
• Customer Support Providers: To assist with customer inquiries and support.
• Analytics Providers: To help us understand how our Services are used and improve them.
• Marketing and Advertising Partners: To deliver targeted advertising and marketing communications, where permitted by law and your preferences.
• IT and Security Consultants: To maintain and enhance the security and integrity of our systems.

These service providers are contractually obligated to protect your Personal Data and are prohibited from using it for any purpose other than providing services to us.

3.3 For Legal and Compliance Reasons

We may disclose your information if we believe it is necessary to:

• Comply with any applicable law, regulation, legal process, or governmental request.
• Enforce our Terms of Service, including investigation of potential violations.
• Detect, prevent, or otherwise address fraud, security, or technical issues.
• Protect the rights, property, or safety of Ognimohub, our users, or the public as required or permitted by law.

3.4 Business Transfers

In the event of a merger, acquisition, reorganization, bankruptcy, or sale of all or a portion of our assets, your Personal Data may be transferred as part of that transaction. We will notify you via email and/or a prominent notice on our website of any such change in ownership or control of your Personal Data.

3.5 Aggregated or Anonymized Data

We may share aggregated or anonymized information that cannot reasonably be used to identify you with third parties for various purposes, including research, analytics, and marketing.

4. International Data Transfers

Ognimohub operates globally, and your Personal Data may be stored and processed in any country where we have facilities or where we engage service providers. This means your information may be transferred to, and processed in, countries other than the country in which you reside, including countries outside the European Economic Area (EEA) that may not provide the same level of data protection as your home country.

When we transfer your Personal Data internationally, we take appropriate safeguards to ensure your data is protected in accordance with this Privacy Policy and applicable data protection laws. These safeguards may include:

• Standard Contractual Clauses (SCCs): Implementing SCCs approved by the European Commission or other relevant authorities.
• Adequacy Decisions: Relying on adequacy decisions from the European Commission regarding certain countries.
• Binding Corporate Rules (BCRs): For transfers within our corporate group, if applicable.
• Your Consent: Obtaining your explicit consent for specific transfers.

By using our Services, you understand and agree that your Personal Data may be transferred to and processed in countries outside your country of residence.

5. Data Retention

We retain your Personal Data for as long as necessary to fulfill the purposes for which it was collected, including for the purposes of satisfying any legal, accounting, or reporting requirements. The retention period may vary depending on the type of data and the purpose of processing.

Factors influencing our retention periods include:

• Legal and Regulatory Obligations: We are required to retain certain transaction records and identity verification information for specific periods to comply with AML, KYC, and tax laws.
• Contractual Obligations: Data necessary to provide our Services and fulfill our contractual obligations to you.
• Dispute Resolution: Data may be retained for the establishment, exercise, or defense of legal claims.
• Security and Fraud Prevention: Data may be retained to prevent fraud and enhance security.
• Business Needs: Data needed for internal analytics, reporting, and business operations.

When your Personal Data is no longer required, we will securely delete or anonymize it in accordance with applicable laws and our data retention policies.

6. Your Data Protection Rights

Depending on your jurisdiction, you may have the following rights regarding your Personal Data:

6.1 Right to Access (Right to Know)

You have the right to request access to the Personal Data we hold about you and to receive a copy of that information.

6.2 Right to Rectification (Correction)

You have the right to request that we correct any inaccurate or incomplete Personal Data we hold about you.

6.3 Right to Erasure (Right to Be Forgotten)

You have the right to request the deletion of your Personal Data under certain circumstances, such as when the data is no longer necessary for the purposes for which it was collected, or if you withdraw your consent. Please note that we may be legally obligated to retain certain information for a specific period.

6.4 Right to Restriction of Processing

You have the right to request that we restrict the processing of your Personal Data under certain conditions, for example, if you contest the accuracy of the data or object to its processing.

6.5 Right to Data Portability

You have the right to receive your Personal Data in a structured, commonly used, and machine-readable format and to transmit that data to another controller, where technically feasible.

6.6 Right to Object

You have the right to object to the processing of your Personal Data based on our legitimate interests or for direct marketing purposes.

6.7 Right to Withdraw Consent

Where we rely on your consent to process your Personal Data, you have the right to withdraw that consent at any time. Withdrawal of consent will not affect the lawfulness of processing based on consent before its withdrawal.

6.8 Right to Lodge a Complaint

You have the right to lodge a complaint with a supervisory authority, particularly in the country of your habitual residence, place of work, or place of the alleged infringement, if you believe that our processing of your Personal Data infringes applicable data protection laws.

6.9 Exercising Your Rights

To exercise any of these rights, please contact us using the details provided in the "Contact Us" section in the menu above. We will respond to your request in accordance with applicable data protection laws. We may need to verify your identity before fulfilling your request.

7. Children's Privacy

Our Services are not directed to individuals under the age of 18, and we do not knowingly collect Personal Data from children. If we become aware that we have inadvertently collected Personal Data from a child under 18, we will take steps to delete such information from our records as quickly as possible. If you believe that a child under 18 has provided us with Personal Data, please contact us immediately.

8. Third-Party Links

Our Services may contain links to third-party websites or services that are not operated by us. We are not responsible for the privacy practices or the content of these third-party sites. We encourage you to review the privacy policies of any third-party sites you visit.

9. Security Measures

We implement robust technical and organizational security measures designed to protect your Personal Data from unauthorized access, disclosure, alteration, and destruction. These measures include:

• Encryption: We use industry-standard encryption protocols (e.g., TLS 1.3 for data in transit, AES-256 for data at rest) to protect sensitive information.
• Access Controls: Strict access controls are in place to limit access to Personal Data to authorized personnel only, based on the principle of least privilege.
• Multi-Factor Authentication (MFA): We encourage and, in some cases, require MFA for account access to add an extra layer of security.
• Regular Security Audits and Penetration Testing: We conduct regular security assessments, vulnerability scans, and penetration tests to identify and address potential weaknesses.
• Firewalls and Intrusion Detection Systems: We employ firewalls and intrusion detection/prevention systems to monitor and protect our networks.
• Data Minimization and Tokenization: We collect and retain only the data necessary for our services and use tokenization for highly sensitive data like payment card numbers.
• Employee Training: Our employees receive regular training on data protection and security best practices.

While we strive to protect your Personal Data, no method of transmission over the internet or method of electronic storage is 100% secure. Therefore, we cannot guarantee its absolute security.

10. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, technology, legal requirements, or other factors. We will notify you of any material changes by posting the updated policy on our website and updating the "Last Updated" date at the top of this policy. We encourage you to review this Privacy Policy periodically to stay informed about how we are protecting your information.

11. Contact Us

If you have any questions, concerns, or requests regarding this Privacy Policy or our data practices, please contact our Data Protection Officer at:

Ognimohub Data Protection Officer Email: privacy@ognimohub.com

We are committed to working with you to obtain a fair resolution of any complaint or concern about privacy.