Privacy Policy

Last updated: 1 June 2025

Your privacy matters to us. This policy explains what personal information we collect, how we use it, who we share it with, and the rights you have over your data. Please read it carefully.

01 Who We Are

Sunu Pay is a mobile payments platform operated by Sunu Pay Ltd ("we," "us," or "our"). We are the data controller responsible for your personal information.

If you have any questions about this policy or how we handle your data, you can reach us at info@sunupay.app.

02 Information We Collect

We collect the following types of personal information so we can provide our services safely and legally.

Information you give us

  • Your full name, date of birth, and contact details such as phone number and email
  • Identity documents and verification information required by law (such as a passport or national ID)
  • Payment information, including the details of transactions you make
  • Any information you provide when you contact our support team

Information we collect automatically

  • Device information, such as your device type and operating system
  • App usage data, such as the features you use and when
  • Technical data, such as your IP address and general location

Information from others

  • Identity and fraud-prevention checks from verification partners
  • Information from financial institutions and payment partners needed to process your transactions

03 How We Use Your Information

We use your personal information to:

  • Create and manage your account
  • Process your payments and transactions
  • Verify your identity and prevent fraud and financial crime
  • Meet our legal and regulatory obligations
  • Provide customer support and respond to your questions
  • Improve our app, services, and security
  • Send you important service updates and, where you agree, marketing messages

04 Our Lawful Basis

Under UK data protection law, we must have a valid reason for using your personal information. We rely on the following:

  • Performance of a contract: to provide the services you sign up for
  • Legal obligation: to meet anti-money laundering, fraud-prevention, and other regulatory requirements
  • Legitimate interests: to keep our service secure, prevent fraud, and improve what we offer
  • Consent: for optional things like marketing, which you can withdraw at any time

05 Who We Share It With

We do not sell your personal data. We only share it where necessary to run our service or to meet our legal duties, including with:

  • Payment processors and financial institutions that help complete your transactions
  • Identity verification and fraud-prevention partners
  • Technology providers that host and support our app securely
  • Regulators, law enforcement, and authorities where we are legally required to do so
  • Professional advisers such as auditors and lawyers, where needed
Every partner we share data with is required to protect it and use it only for the purposes we specify.

06 International Transfers

Because we help you move money worldwide, your information may sometimes be transferred to and processed in countries outside the UK.

Whenever we do this, we make sure appropriate safeguards are in place to protect your data to the same standard required under UK data protection law, such as approved contractual clauses.

07 How Long We Keep It

We keep your personal information only for as long as necessary to provide our services and to meet our legal obligations.

For example, anti-money laundering laws require us to keep certain transaction and identity records for a minimum of five years after our relationship with you ends. After this period, we securely delete or anonymise your data.

08 How We Protect It

We take the security of your data seriously and use strong measures to protect it, including:

  • Bank grade encryption of your data in transit and at rest
  • Multi factor authentication on accounts
  • Continuous monitoring for fraud and unauthorised access
  • Strict internal access controls so only authorised staff can access data

While we work hard to protect your information, no system can be guaranteed completely secure. You also play an important part by keeping your login details private.

09 Your Rights

Under UK data protection law, you have the following rights over your personal information:

Access

Ask for a copy of the personal data we hold about you.

Correction

Ask us to correct information that is wrong or incomplete.

Deletion

Ask us to delete your data where we no longer need it.

Restriction

Ask us to limit how we use your data in certain cases.

Objection

Object to us using your data for certain purposes.

Portability

Ask to receive your data in a portable format.

To exercise any of these rights, email us at info@sunupay.app. We will respond within one month. Some rights may not apply where we are legally required to keep your information.

10 Cookies

Our website uses cookies and similar technologies to make the site work, understand how it is used, and improve your experience.

You can control cookies through your browser settings and through any cookie banner shown on our site. Turning off some cookies may affect how the website works.

11 Children's Privacy

Sunu Pay is not intended for anyone under 18 years of age. We do not knowingly collect personal information from children. If we learn that we have collected data from someone under 18, we will delete it promptly.

12 Changes to This Policy

We may update this policy from time to time. When we make significant changes, we will update the date at the top of this page and, where appropriate, notify you by email or within the app.

We encourage you to review this policy regularly so you stay informed about how we protect your information.

13 Contact and Complaints

If you have any questions about this policy or want to exercise your rights, please contact us:

  • Email: info@sunupay.app
  • Website: www.sunupay.app/contact

If you are unhappy with how we have handled your personal data, you have the right to complain to the UK's data protection regulator.

Information Commissioner's Office (ICO)

The ICO is the UK's independent authority for data protection. You can contact them if you have concerns about how we use your information.

Website: ico.org.uk

Helpline: 0303 123 1113