Privacy Policy

1. Data Controller

2. Scope

This Policy applies to the XurmoPay mobile application, related web pages, and customer support communications. It does not replace agreements you may have with your bank or payment provider.

3. Data We Collect

3.1 Personal Information

• Full name
• Phone number
• Email address
• Date of birth (where required)
• Identity verification (KYC) details where required by law (e.g., ID/passport data)

3.2 Financial & Transaction Information

• Transaction history and transfer details
• Wallet/account balance and status (where applicable)
• Linked payment method identifiers in masked form (e.g., last digits)

3.3 Technical & Security Information

• Device type, operating system version, app version
• Device identifiers used for authentication/security (e.g., Android ID)
• IP address (processed in anonymized/aggregated form where feasible)
• Crash logs, diagnostics, and security events

4. How We Use Data

• To provide app functionality (registration, authentication, account access)
• To enable payment/transfer features and process your requests
• To prevent fraud, detect suspicious activity, and protect users
• To comply with legal and regulatory requirements (including KYC/AML, where applicable)
• To provide customer support and service communications
• To improve stability, performance, and security of the App

5. Legal Basis

We process personal data based on one or more of the following legal grounds:

• Your consent (where required)
• Performance of a contract / providing requested services
• Compliance with legal obligations (including financial regulations)
• Legitimate interests (security, fraud prevention, service improvement), where permitted

6. Sharing Data with Third Parties

We may share data strictly when necessary with:

• Licensed banks and financial institutions
• Payment service providers and processing partners
• Identity verification (KYC) and fraud prevention providers
• Regulators, law enforcement, or authorities when required by law

We do not sell or rent personal data to third parties for advertising purposes.

7. Data Security

We implement reasonable technical and organizational measures designed to protect information against unauthorized access, alteration, disclosure, or loss. Data is encrypted in transit (e.g., via HTTPS/TLS). Access to personal data is restricted to authorized personnel.

8. Data Retention

We retain personal data only for as long as necessary to provide services and meet legal, accounting, and regulatory requirements. Retention periods may vary depending on the type of data and applicable laws.

9. Your Rights

Depending on your jurisdiction, you may have rights to:

• Request access to your personal data
• Request correction or deletion (where applicable)
• Withdraw consent (where processing is based on consent)
• Object to certain processing activities (where applicable)

To submit a request, email us at info@xurmopay.com.

10. Children’s Privacy

XurmoPay is not intended for individuals under 18 years of age. We do not knowingly collect personal data from minors.

11. Platform Status and Responsibilities

XurmoPay operates as a financial technology platform. Transfers and payment transactions are executed by licensed banks and/or payment service providers in accordance with their rules and applicable regulations. Xurmo TOO is not a bank unless explicitly stated otherwise.

12. Changes to This Policy

We may update this Policy from time to time. The updated version will be published at this URL and will include an updated “Last updated” date.

13. Contact Us

Xurmo TOO
010000, Kazakhstan, Astana, Saryarka District, Ықылас Дүкенұлы St., 38/1, Apt. 55
Phone: +77081782009
Email: info@xurmopay.com