Legal
Privacy Policy
Myrica Pay, LLC.
Version: 2.0
Effective Date: March 2026
Last Updated: March 2026
Our Promise to You
Your trust is the most important thing we hold. This Privacy Policy explains clearly and honestly how Myrica Pay collects, uses, stores, shares, and protects your personal information when you use our platform, mobile application, and all related services.
We believe you have the right to know exactly what happens to your data - in plain language, not legal jargon. Our approach to privacy is built on our Principle of Digital Trust: we only collect what we need, we protect it like it is our own, and we never sell it.
This Policy has been designed to comply with the Bank of Sierra Leone's Financial Consumer Protection Guidelines, applicable data protection laws in each market where we operate, and international best practices including the principles of the General Data Protection Regulation (GDPR) and the ECOWAS Supplementary Act on Personal Data Protection.
By creating a Myrica Pay account or using any of our Services, you confirm that you have read and understood this Privacy Policy.
1. Who We Are
Myrica Pay, LLC. is the data controller responsible for your personal information.
Registered Address
71 Roberts Street, Freetown, Sierra Leone
Contact
Email: privacy@myricapay.app
Support: support@myricapay.app
Phone: +232 76 312 244
Website: myricapay.app
Myrica Pay is currently licensed and operational in Sierra Leone under the oversight of the Bank of Sierra Leone, with regulatory applications pending in the Gambia, Liberia, and Guinea. Where you are registered in a country other than Sierra Leone, Myrica Pay processes your data in accordance with the applicable laws of your registered country as well.
2. Who This Policy Applies To
This Privacy Policy applies to:
- Individual customers who create a personal Myrica Pay account
- Merchants who register to accept Myrica Pay payments
- Agents who join the Myrica Pay agent network
- Visitors to our website at myricapay.com
- Anyone who contacts us through any of our communication channels
If you are under 18 years of age, you are not permitted to use Myrica Pay. We do not knowingly collect personal data from anyone under the age of 18. If we discover that we have collected data from a minor, we will delete it immediately.
3. The Information We Collect and Why
We only collect personal data that is genuinely necessary to provide our Services safely, legally, and effectively. Here is exactly what we collect and why:
3.1 Identity and Account Information
What we collect:
Your full legal name, phone number, email address, date of birth, nationality, residential address, and a copy of your government-issued photo identification such as a passport, national ID card, or driver's licence. We also collect biometric information - specifically a 3D selfie - during the account setup and verification process.
Why we collect it:
To verify that you are who you say you are, create and maintain your account securely, comply with our mandatory Know Your Customer (KYC) obligations under applicable AML/CFT law, and prevent fraud and identity theft.
Legal basis:
Legal obligation (KYC/AML compliance) and contract performance (account creation and service delivery).
3.2 Financial and Transaction Information
What we collect:
Details of your funding sources such as debit card or bank account information, wallet balance information, transaction amounts, recipient details, transaction timestamps, payment references, and transaction history.
Why we collect it:
To process your payments accurately, securely, and in accordance with your instructions. To generate receipts, statements, and transaction records. To meet our regulatory reporting obligations.
Legal basis:
Contract performance and legal obligation.
3.3 Device and Technical Information
What we collect:
Your device type and model, operating system and version, unique device identifiers, IP address, app version, crash reports, session data, and general usage patterns within the app.
Why we collect it:
To protect your account from unauthorised access, detect and prevent fraud, troubleshoot technical issues, maintain platform security, and improve the performance of the app.
Legal basis:
Legitimate interests (security and fraud prevention) and contract performance.
3.4 Location Information
What we collect:
General location data derived from your IP address or, where you grant explicit permission, more precise location data from your device's GPS.
Why we collect it:
To verify that transactions are consistent with your normal behaviour, support fraud detection, and where relevant, help you find nearby Myrica Pay agents.
Legal basis:
Consent (for precise GPS location) and legitimate interests (for general IP-based location used in fraud prevention).
You can withdraw your consent for precise location access at any time through your device settings. Withdrawing location consent does not affect your ability to use core Myrica Pay features.
3.5 Communications Data
What we collect:
Records of your communications with our support team, including emails, in-app messages, and phone call logs where applicable.
Why we collect it:
To resolve your queries, maintain records of commitments made, improve our support quality, and comply with our complaints handling obligations.
Legal basis:
Contract performance and legitimate interests.
3.6 Marketing and Preference Data
What we collect:
Your communication preferences, including whether you have opted in or out of marketing communications, and your language and notification preferences.
Why we collect it:
To send you only the communications you have agreed to receive, and to respect your choices about how we contact you.
Legal basis:
Consent. You can change your marketing preferences at any time through the app settings or by contacting support@myricapay.app.
We will never send you unsolicited marketing communications. We will always ask for your explicit consent before adding you to any marketing list.
4. How We Use Your Information
In addition to the specific purposes listed above, we use your personal data to:
- Operate, maintain, and improve the Myrica Pay platform and Services
- Verify your identity and manage your KYC verification status
- Process and complete your transactions
- Detect, investigate, and prevent fraud, money laundering, and other financial crimes
- Comply with all applicable legal and regulatory obligations in each operating market
- Respond to your support requests and complaints
- Send you important service notifications such as transaction receipts, security alerts, and policy updates - these are not marketing and cannot be opted out of while your account is active
- Conduct internal analytics to understand how the platform is used and where it can be improved
- Train and support our compliance and fraud detection systems
- Enforce our Terms of Service
We do not use your personal data to make automated decisions that have a significant legal or material effect on you without human review.
5. How We Protect Your Data
Protecting your information is built into the foundation of our platform. We apply the following security measures:
Encryption
All data is encrypted both in transit and at rest using industry-standard AES 256-bit encryption. All data transmitted between your device and our servers uses TLS (Transport Layer Security).
Access Controls
We operate on a strict principle of least privilege. Our employees and contractors can only access the specific data they need to perform their specific job function. All access is logged, monitored, and regularly audited.
Secure Infrastructure
Our platform is built on enterprise-grade cloud infrastructure through AWS and is being developed in compliance with PCI DSS standards for card data and ISO 27001 standards for information security management.
Biometric Security
Biometric data collected during KYC verification is processed by our verified KYC biometric partner, using liveness detection technology. Biometric data is not stored as a raw image - it is converted into an encrypted mathematical representation that cannot be reverse-engineered.
Independent Security Audits
We conduct regular external security audits and penetration tests to identify and remediate vulnerabilities before they can be exploited.
Fraud Monitoring
Our platform runs continuous automated monitoring to detect suspicious activity, unusual transaction patterns, and potential account compromises in real time.
Despite our best efforts, no system is completely immune to risk. If you suspect your account has been compromised, contact us immediately at support@myricapay.app.
6. How We Share Your Information
We will never sell your personal data to any third party. We do not share your data for advertising or commercial profiling purposes.
We only share data in the following limited and necessary circumstances:
- Identity Verification Partners: We share your identity documents and biometric data with our KYC biometric partner, solely for the purpose of verifying your identity during account setup and ongoing verification checks.
- Banking and Payment Partners: We share transaction data with our licensed banking partners and global payment network providers, to the extent necessary to process and complete your transactions. These partners are contractually obligated to process your data only for the specific purpose for which it was shared.
- Mobile Money and Agent Network Partners: We share limited transaction data with mobile money operators and partner financial institutions to facilitate local and cross-border payment routing.
- Regulatory and Law Enforcement Authorities: We may be required by law to share information with the Bank of Sierra Leone, Financial Intelligence Units, law enforcement agencies, or other regulatory bodies. We will only do so when lawfully required and will not notify you of such disclosure where prohibited by law.
- Professional Advisors: We may share data with our legal advisors, auditors, and accountants where necessary, under strict confidentiality obligations.
- Business Transfers: If Myrica Pay is involved in a merger, acquisition, or sale of assets, your data may be transferred as part of that transaction. We will notify you before your data is transferred and becomes subject to a different privacy policy.
All third-party partners who process personal data on our behalf are subject to data processing agreements that require them to maintain at least the same standards of privacy and security that we apply ourselves.
7. Cross-Border Data Transfers
Myrica Pay operates across multiple countries and processes cross-border transactions. This means that your data may be processed or stored in a country different from where you are located, including countries outside your home jurisdiction.
Where we transfer data across borders, we ensure that appropriate safeguards are in place to protect your information in accordance with applicable law. These safeguards may include contractual protections with our partners, compliance with ECOWAS data protection frameworks, and adherence to equivalent international standards.
By using Myrica Pay, you acknowledge that your data may be transferred to and processed in countries where data protection laws may differ from those in your home country. We always apply our own standards regardless of where data is processed.
8. Cookies and Tracking Technologies
Myrica Pay uses cookies and similar tracking technologies on our website at myricapay.com.
What are cookies?
Cookies are small files placed on your device when you visit a website. They help the website remember your preferences and understand how you use it.
Types of cookies we use:
Essential Cookies
Required for the website to function. These cannot be disabled. They include session management and security cookies.
Analytics Cookies
Help us understand how visitors use our website - which pages are visited most, where users come from, and how they navigate. We use this data only to improve the website experience. We use anonymised analytics where possible.
Preference Cookies
Remember your language and display preferences so you do not have to reset them on each visit.
Marketing Cookies
We do not use marketing or advertising tracking cookies on our website. We do not allow third-party advertising networks to place cookies on our site.
You can manage your cookie preferences through your browser settings at any time. Disabling essential cookies may affect your ability to use certain website features. Our Cookie Policy, available at myricapay.com/cookies, contains full details.
9. Your Rights Over Your Data
You have the following rights in relation to your personal data. To exercise any of these rights, contact us at privacy@myricapay.app. We will acknowledge your request within 5 business days and provide a full response within 30 calendar days.
Right to Access
You can request a copy of the personal data we hold about you, along with information on how it is being used.
Right to Correction
If any personal data we hold about you is inaccurate or incomplete, you can request that we correct it.
Right to Deletion
You can request that we delete your personal data. We will do so where we are not required by law to retain it. Please note that AML/CFT regulations require us to retain KYC and transaction records for a minimum of five years regardless of any deletion request.
Right to Restrict Processing
You can ask us to stop using your data for certain purposes while a dispute or review is in progress.
Right to Data Portability
You can request a copy of your personal data in a commonly used, machine-readable format so that you can transfer it to another service provider where technically feasible.
Right to Object
You can object to the processing of your data where we are relying on legitimate interests as the legal basis, including for fraud detection analytics. We will honour this unless we have compelling legitimate grounds that override your interests.
Right to Withdraw Consent
Where we are processing your data on the basis of your consent - such as for marketing communications or precise GPS location - you can withdraw that consent at any time. Withdrawal does not affect the lawfulness of processing that occurred before withdrawal.
Right to Complain
If you are not satisfied with how we have handled your data, you have the right to lodge a complaint with the Bank of Sierra Leone or the relevant data protection or financial regulatory authority in your country of registration.
10. Data Retention
We retain your personal data only for as long as is necessary for the purposes for which it was collected and to comply with our legal obligations.
The following retention guidelines apply:
- KYC and Identity Verification Records: Minimum 5 years from the date of account closure, as required by AML/CFT regulations in Sierra Leone and applicable markets.
- Transaction Records: Minimum 5 years from the date of each transaction, as required by applicable financial services law.
- Account Information: Retained for the duration of your account and for 5 years after closure.
- Support and Communications Records: Retained for 3 years from the date of the communication.
- Device and Technical Logs: Retained for up to 12 months for security and fraud analysis purposes.
- Marketing Preference Records: Retained for as long as your account is active and for 2 years after closure for compliance record-keeping.
After the applicable retention period, data is securely and permanently deleted or irreversibly anonymised. We do not retain data beyond what is legally required or operationally necessary.
11. Data Breach Notification
In the event of a personal data breach that is likely to result in a risk to your rights and freedoms, Myrica Pay will:
- Notify the relevant regulatory authority in each affected market within 72 hours of becoming aware of the breach, where required by law
- Notify affected users directly as soon as reasonably practicable where the breach is likely to result in a high risk to your personal rights
- The notification will describe the nature of the breach, the data involved, the likely consequences, and the steps we are taking to address it
- Maintain a full internal record of all data breaches regardless of whether regulatory notification is required
We take all suspected data breaches seriously. If you believe your Myrica Pay account or personal data has been compromised, please contact us immediately at security@myricapay.app.
12. Children's Privacy
Myrica Pay is not designed for or directed at children under the age of 18. We do not knowingly collect, store, or process personal data relating to anyone under 18 years of age.
If you are a parent or guardian and believe that your child has provided us with personal data, please contact us immediately at privacy@myricapay.app and we will delete that information promptly.
13. Third-Party Links and Services
Our website and app may contain links to third-party websites, services, or products. This Privacy Policy does not apply to those third-party services. We are not responsible for the privacy practices of any website or service we do not operate. We encourage you to review the privacy policies of any third-party service you visit or use.
14. Changes to This Privacy Policy
We may update this Privacy Policy from time to time to reflect changes in our Services, applicable law, or our data practices. When we make material changes, we will notify you by email, in-app notification, or prominent notice on our website at least 14 days before the changes take effect.
The updated version will always show the effective date at the top of this page. Your continued use of the Services after the effective date of an updated Policy constitutes your acknowledgement of the changes.
A record of previous versions of this Privacy Policy is available on request by contacting privacy@myricapay.app.
15. Accessibility
This Privacy Policy is always accessible from our website at myricapay.com/privacy, within the Myrica Pay app under Settings, and on our app store listings. We are committed to ensuring this document is available in plain language at all times.
If you need this Policy in a different format or language, please contact us and we will do our best to accommodate your request.
16. How to Contact Us
For any questions, concerns, or requests relating to this Privacy Policy or your personal data, please contact us:
Privacy and Data Protection:
General Support:
Security Concerns:
Post:
Myrica Pay, LLC.
13 Dundas Street, Freetown, Sierra Leone
Freetown, Sierra Leone
Phone:
+232 76 312244
Website:
myricapay.com
If you are not satisfied with our response to a privacy concern, you have the right to escalate to the Bank of Sierra Leone or the relevant regulatory authority in your country of registration.
© 2026 Myrica Pay, LLC. All rights reserved.
Myrica Pay provides digital financial services under regulatory supervision in each active market. Features and availability may vary by country and are subject to local law.
Sierra Leone | The Gambia | Liberia | Guinea