Privacy Notice

1. Who is responsible

KoboPayments Limited, an Irish company that is currently being incorporated, is the controller of the personal data described here. Contact for privacy questions and requests: Supportwithkobo@gmail.com.

2. What we collect

Account details: name, email address, phone number (stored as given, not verified) and country. Your password is handled by our authentication provider and your PIN is stored only in hashed form.

When you claim money: your relationship to the sender, if you give one, and when you accepted our terms and this notice.

Transaction data: amounts, dates, status, and the people you send money to or request money from, including the email address or phone number a sender enters for someone not yet on Kobo. We also keep the recipients you save.

Cash-out details, only if you start a cash-out: bank, account number and account name, which we save for reuse. An optional Bank Verification Number (BVN) is passed to the payout partner for that cash-out and is not stored.

Technical data: your IP address, used when setting up a payment session and recorded in hosting logs. Our hosting provider may log IP addresses for a short time to keep the service secure and running. We do not store your IP address with your waitlist answers or with our own product analytics.

Analytics: our website and our test site use PostHog (posthog.com), a product analytics service hosted in the EU, to count visits and see where people stop. It sets no cookies, it does not record your screen or your session, and we have set it not to store your IP address. It receives the page you visit (without any link token or query), the address of the site that sent you, the campaign details in the link you used and a friend's code if the link had one (a code, never a name or email address), a few coarse events such as viewing or joining the waitlist (your role and monthly range, never your email address or name), page speed measurements, and a count of errors. We do not send it your email address, name, amounts, wallet address or account number. If your browser sends a Do Not Track or Global Privacy Control signal, we send it nothing.

What the site keeps on your device: while you browse, the site keeps a short note in your browser tab for the visit. It holds the campaign details and the friend's code from the link you arrived on, and the address of the site that sent you. We use it to add where you came from to our visit counts and, if you join the waitlist, to your signup. It is cleared when you close the tab. This note is kept even if your browser sends a Do Not Track or Global Privacy Control signal, because the waitlist signup uses it too. People on the Kobo team and testers who open the site with a ?internal=1 link also have a plain on or off flag saved on their own device, so we can leave their visits out of our counts. It holds no personal data.

Feedback: if you send us feedback through the site, it is sent to our server and stored with the page it came from and, if you add one, your email address so we can reply. We also receive it by email. We do not store your IP address or browser details with it.

When you join the waitlist we collect: your email address (required); your first name (optional); whether you want to send money or receive it; roughly how much you send each month (optional); how you send money today (optional); whether you agreed to hear from us about Kobo and when; whether you would like to help build Kobo; where you came from (the campaign details in the link you used, such as utm_source, utm_medium and utm_campaign) and the personal code of the friend who invited you, if any (if you join, the campaign details and the friend's code from your link are saved with your signup); and the date and time you joined. When you share your own link from the thank-you page, it contains your code and the name of the app you shared it with (for example whatsapp), never your name or email address. We use this to run the waitlist, decide who is invited to try Kobo, understand who Kobo is for, and, only if you agreed, send you news about Kobo. We use your answers about how you send money to design the product. We do not sell your data and we do not use it to advertise to you elsewhere. Who can see it: Kobo's founders, and the services that host and send our emails for us (our database, website hosting and email providers). We do not store your IP address with your answers. You can ask us to see, correct or delete your waitlist data, or take back your marketing agreement at any time, by emailing Supportwithkobo@gmail.com. We keep waitlist data for as long as the closed beta runs and delete it within 12 months of the beta ending unless you ask us to delete it sooner. Invitations to try the beta are not marketing and do not need your marketing agreement.

3. Why we use it

To run your account and sign you in, process payments and cash-outs, email you claim links, prevent fraud and misuse, meet legal obligations, and contact you about the service. We do not sell your personal data.

We use your waitlist details to invite you to try the closed beta and, only if you agreed, to send you news about Kobo.

4. Who we share it with

Providers that process data for us: Supabase (database and authentication), Railway and Vercel (hosting) and Resend (email).

Payment partners, by category: providers that process top-ups, and a payout partner that verifies bank accounts and pays out to Nigerian bank accounts. They receive what they need to process the payment and may collect information from you under their own notices.

The sender of a transfer may see the name you gave when you claimed it, and you see theirs. Blockchain transactions, including wallet addresses and amounts, are public and cannot be deleted; we do not put your name or contact details on the blockchain. We may also disclose data where the law requires it.

Some providers may process data outside the European Economic Area, and cash-outs involve a partner serving Nigeria.

5. How long we keep it

We keep account and transaction records while your account is open, and afterwards for as long as needed for legal and security reasons.

Waitlist data is kept while the closed beta runs and is deleted within 12 months of it ending, or sooner if you ask.

6. Your rights

You can ask to access, correct or erase your personal data, restrict or object to its use, and receive it in a portable format, subject to legal exceptions such as records we must keep. You can ask us to delete your saved recipients at any time. Email Supportwithkobo@gmail.com.

You can complain to the Data Protection Commission in Ireland (dataprotection.ie).

7. Changes

We will update this notice when our practices change and show the date of the latest version above.