Privacy Policy

Last Updated: November 2025

This Privacy Policy ("Policy") governs the manner in which Pincode ("Company", "we", "our", "us") collects, processes, uses, stores, shares, and protects information relating to individuals and merchants ("User", "you", "your") who access or use our website, mobile application, APIs, or any related services ("Services").

This Policy is prepared in accordance with:

The Prevention of Electronic Crimes Act (PECA), 2016
The Personal Data Protection Bill of Pakistan (where applicable)
SECP AML/CFT Guidelines
Applicable data protection and privacy regulations

By using the Services, you expressly consent to the processing of your personal data in accordance with this Policy.

1. Introduction

This Policy explains what information we collect, why we collect it, how we use it, and the choices you have about your information.

2. Categories of Data Collected

2.1 Personal Identification Data

Full name
CNIC/NICOP number
Date of birth
Contact number
Email address
Residential or business address

2.2 Business Information

Business name and registration details
NTN/Tax information
Nature of business
Business documentation (if applicable)
Bank account details

2.3 KYC/Verification Documents

CNIC front and back
Live selfie (for biometric verification)
Proof of business (SECP certificate, bank letter, tax certificate, etc.)
Signature or corporate stamp (if required)

2.4 Transaction & Financial Data

Payment requests
Wallet balances
Settlement history
Payout details
Third-party wallet identifiers (Easypaisa, JazzCash, Zindigi, etc.)

2.5 Technical & Behavioral Data

IP address
Device identifiers
Browser information
Access logs
Usage patterns
Geo-location (if permitted by device)

3. Legal Basis for Processing

We process your data under the following lawful bases:

Performance of Contract: To provide payment and wallet services
Legal Obligation: AML, KYC, SECP reporting compliance
Legitimate Interest: Fraud prevention, service enhancement
Consent: Marketing communications, optional features

4. Purpose of Processing

Your data is used for:

Identity and business verification (KYC/CDD)
Activation and maintenance of your merchant wallet
Payment processing, settlements, and payouts
Risk assessment, anti-fraud, AML/CFT compliance
Customer support and dispute resolution
Providing analytics, insights, and dashboard features
Regulatory reporting
System security, performance enhancement, and audits

We do not sell or trade your personal data to any unaffiliated third party.

5. Data Sharing and Disclosure

We may share your information with:

5.1 Payment Networks & Financial Institutions

Easypaisa
JazzCash
Zindigi
Banks and settlement partners

For the purpose of executing payments, settlements, and verifications.

5.2 Regulatory Bodies

Upon lawful request:

SECP
SBP (if required through partner banks)
FIA Cyber Crime Wing
Law enforcement agencies

5.3 Third-Party Service Providers

For:

Cloud hosting
Fraud detection
KYC verification
Analytics
Customer support

All such providers act under strict confidentiality obligations.

6. Data Retention

KYC data for minimum 5 years post-termination
Transaction data for 7 years (regulatory requirement)
Account information until legally permissible or upon closure

Data may be retained longer in case of legal disputes or investigations.

7. Data Security

We implement:

End-to-end encryption
Secure socket layer (SSL)
Multi-factor authentication
Role-based access control
Continuous monitoring
Audit logging
Tokenization of sensitive data

Despite our efforts, no system is fully immune from risks.

8. User Rights

You may:

Request access to your data
Request rectification
Request deletion subject to regulatory obligations
Request restriction on processing
Withdraw consent for non-essential processing
Lodge a complaint with the relevant authority

9. International Data Transfer

If your data is processed outside Pakistan, it is done only in jurisdictions with adequate data protection standards.

10. Changes to Policy

We reserve the right to amend this Policy at any time. Continued use of Services constitutes acceptance of modifications.

11. Contact

Email: support@pincode.pk