Last Updated: May 22, 2025

1. Scope

This unified Privacy Policy describes how HoneyCoin, Inc. and its affiliated subsidiaries – including our products HoneyCoin for Business (accessible via honeycoin.app), Peer (via usepeer.co), and Cashless (via wearecashless.com) – (collectively, "HoneyCoin," "Peer," "Cashless," "we," "us," or "our") collect, use, disclose, and protect your personal information. It applies to all services we provide, including banking services, cross-border payments, treasury management, and related financial services offered through our websites, mobile applications, APIs, and other online platforms (collectively, the "Services" or "Sites"). This policy is global in scope: while HoneyCoin’s operations are primarily based in Africa, we also serve users in the European Union (EU) and the United States. We therefore adhere to applicable data protection laws in all jurisdictions where we operate, including the EU General Data Protection Regulation (GDPR), the California Consumer Privacy Act and California Privacy Rights Act (CCPA/CPRA), Nigeria’s Data Protection Regulation, Kenya’s Data Protection Act, and other relevant national laws, as applicable. This Privacy Policy applies regardless of the means you use to access our Services (web or mobile). Capitalized terms used but not defined in this Privacy Policy have the meanings given to them in our User Agreement.

Effective Date: If you created a HoneyCoin account prior to February 25, 2025, this updated Privacy Policy is effective from that date. For all others, this Privacy Policy is effective immediately.

2. Types of Data We Collect

We collect and process various categories of Personal Data in order to provide and improve our Services. The types of information we collect include:

• Information You Provide to Us: This includes any information you directly share when using our Services or communicating with us, such as:
  • Identity and Contact Information: e.g. your name, date of birth, user ID or username, email address, postal address, phone number, and any contact lists you choose to import.
  • Financial and Account Information: e.g. bank account details, payment card numbers, financial account information, transaction history, account balances, payment details, billing information, tax identification numbers, and credit or financial profile information.
  • Identity Verification Data: e.g. government-issued identification documents (passports, driver’s licenses, national ID cards), social security or tax IDs, utility bills, selfies or photographs for identity verification, and any other information required to verify your identity and comply with Know Your Customer (KYC) and Anti-Money Laundering (AML) laws.
  • Authentication Information: e.g. passwords, PINs, security questions/answers, and any biometric identifiers (such as fingerprint or facial recognition data) that you use for authentication.
  • Profile and Preferences: e.g. information in your user profile (such as your display name or avatar), your communication preferences, account settings, and responses to any surveys or questionnaires you choose to complete.
  • Communications: e.g. the content of your communications with us, including emails, customer support requests, feedback, and dispute resolution correspondence.
  • Transactional Information: e.g. details about payments or transfers you make or receive via our Services, such as the amount, date and time, recipient information, currency, and any descriptions or metadata associated with each transaction.
  • Marketing Information: e.g. your preferences for receiving marketing or promotional communications, and information about your engagement with our marketing communications (like whether you opened an email).
• Information We Collect from Third Parties: We may receive information about you from business partners and other external sources, including:
  • Partner Financial Institutions & Payment Processors: For example, if you interact with HoneyCoin through a bank or payment partner, they might provide us with information about you or your transactions (such as to facilitate linking your bank account or to process a payment).
  • Credit Bureaus & Identity Verification Services: These services may provide us with background information to confirm your identity or assess your creditworthiness as part of fraud prevention or compliance checks.
  • Public Databases & Government Registers: We might obtain information from public records (for instance, to verify a business entity or check sanctions lists) and from governmental or regulatory sources for compliance purposes.
  • Marketing and Analytics Providers: We could receive demographic or interest information about users from third-party analytics firms or advertising partners to better tailor our services or marketing.
  • Other Users of our Service: If another user uploads or inputs information about you (for example, by sending you a payment or naming you as a beneficiary or contact), we may collect whatever information they provide about you as part of that transaction.
• Information Automatically Collected: When you access our Sites or use our apps, we (and our service providers or business partners) automatically collect certain technical and usage data through cookies, pixels, and similar tracking technologies. This data includes:
  • Device and Connection Information: Details about the device you use, such as the type of device, operating system and version, hardware model, unique device identifiers, browser type and version, screen resolution, and Internet Protocol (IP) address.
  • Geolocation Data: General location information inferred from your IP address or GPS (with permission), such as city, state, or country. This helps us customize content to your region and detect potential fraud.
  • Usage and Browsing Information: How you interact with our Sites and Services – e.g. which pages or screens you view, the dates/times of access, the amount of time spent on pages, navigation paths between pages, and your referrer URL (the page you came from).
  • Cookies and Similar Technologies: We use cookies and similar tracking tools to remember your preferences and recognize you when you return. These technologies collect data about your browsing activities on our Sites (and possibly other sites) over time, which we use for analytics and advertising purposes. (See Section 3. Cookies and Similar Technologies below for more details.)
  • App and Performance Data: If the app encounters an error or crash, we may collect a crash report and information about the state of the app, device settings, or other diagnostic data to help debug the issue. We also gather performance metrics (like API response times or usage of features) to understand how well the Services are functioning.
  • Telemetry and Analytics Data: This includes data on feature usage and interaction patterns (for example, which buttons or links are clicked) that help us understand user engagement and improve our user interface.
• Information from Social Media and Third-Party Logins: If you choose to engage with HoneyCoin on social media (for example, by visiting our official pages on platforms like LinkedIn, Twitter, or Facebook) or use a third-party login (like “Sign in with Google” or similar single sign-on) to access your HoneyCoin account, we may receive certain information from those third parties. This can include your profile information (such as name, email, or profile picture) and any connections or content you make public on those platforms. The data we receive is governed by the third party’s privacy settings and policies – we only collect what you allow those platforms to share with us. Note that when you interact with our official pages on social networks, the processing of your data is also governed by the privacy policy of the respective platform.
• Sensitive Personal Information: We generally do not intend to collect sensitive personal data such as information about your race or ethnicity, religious or philosophical beliefs, political opinions, union memberships, genetic or biometric data for identification (except as part of optional authentication features), health information, or information about your sex life or sexual orientation. We ask that you not send or upload sensitive personal information to our Services unless it is absolutely necessary for using a specific HoneyCoin service and we have requested it (for example, a government ID which might reveal ethnicity or biometric data for KYC verification). In the limited cases where you do provide or we request sensitive data (e.g. for compliance with law), by providing that information you are consenting to our processing of it for the purposes described at the time. If you do not consent, please refrain from submitting such sensitive information.

3. Cookies and Similar Technologies

What Are Cookies? Cookies are small text files placed on your computer or mobile device when you visit a website. They allow the website to recognize your device and store certain information about your preferences or past actions. We use cookies and similar technologies (such as web beacons, pixels, and device identifiers) to provide, personalize, and improve our Services.

How We Use Cookies: Our Sites use both session cookies (which expire when you close your browser) and persistent cookies (which remain on your device until you delete them or they expire after a set period). Cookies help us in several ways, for example by allowing us to: keep you logged into your account as you navigate through secure areas; remember your site preferences (like language or region); and collect information about how users interact with our Services so we can enhance user experience. We use both first-party cookies (set by HoneyCoin) and third-party cookies (set by service providers or partners) for analytics and advertising. Some cookies are essential for the operation of the Services (for example, to enable security features or authenticate your session), while others are optional and help us personalize content or track aggregate usage statistics.

Your Choices for Cookies: When you first visit our Sites, you will be presented with a notice about our use of cookies and given the option to manage your cookie preferences. You can choose to accept all cookies, reject non-essential cookies, or customize your choices. Additionally, most web browsers allow you to control cookies through their settings (e.g. to block cookies or alert you when cookies are being used). However, please note that if you disable certain categories of cookies, some parts of our Services might not function optimally. For more detailed information on the cookies and tracking technologies we use, and to update your preferences, please see our Cookies Notice (if available on our website) or contact us at [email protected].

4. How We Use Your Personal Data

We use the personal information we collect for the following purposes (or as otherwise described to you at the point of collection):

• To Provide Our Services: We process personal data as necessary to operate and administer the Services and to fulfill our contractual obligations to you. This includes using personal information to:
  • Create, maintain, and service your accounts on our platform.
  • Verify your identity and eligibility for particular services (for example, confirming your identity during sign-up or when linking a bank account).
  • Facilitate and process transactions you request, such as payments, money transfers, and currency exchanges – including to send or receive funds, and to communicate with relevant financial intermediaries (banks, card networks, payment processors) to complete these transactions.
  • Provide customer support and respond to your inquiries, questions, and requests (for example, if you contact us with a question about a transaction or need help with your account).
  • Communicate with you about your account and the Services – this includes sending administrative or account-related messages such as confirmations of transactions, receipts, technical notices, updates, security alerts, and support messages.
  • Enable features that personalize your experience, such as saving your preferences, providing customized account dashboards, and recommending certain features or content based on your usage.
  • Perform risk assessments and fraud monitoring: We use personal and transactional data to detect suspicious or unauthorized activities, to verify that transactions are legitimate, and to mitigate fraud, money laundering, or other financial crimes. This may involve automated analysis of your activity (see Automated Decision Making below).
  • Ensure we comply with legal obligations specifically relevant to financial services, such as KYC/AML regulations and sanctions screening (e.g. checking your data against government sanctions lists and performing required due diligence checks).
  • Fulfill any other purpose for which you provide the information, and carry out any other business or commercial activities that are within the scope of the Services.
• To Improve and Develop Our Services: We continually strive to make our products better. We use personal information for our legitimate interests in improving our existing services and developing new ones. For example, we analyze usage data and feedback to:
  • Debug and troubleshoot technical issues (using data like error logs and crash reports to identify and fix problems).
  • Perform research and analytics on how users interact with our Services, to understand what is working well and what could be improved.
  • Develop new features, products, or services that enhance our offerings or respond to user needs.
  • Test and evaluate potential new products or features (often using aggregated or anonymized data where possible).
  • Conduct customer surveys or research studies (participation is always optional) to gain insights into user satisfaction and preferences.
• To Communicate With You: If you sign up to receive newsletters or marketing communications, or if you have an account with us, we may use your contact information to send you promotional materials about HoneyCoin products or services, as permitted by law. For example, we might send email newsletters about new features, special offers, or events. You will always have the ability to opt out of marketing emails by using the unsubscribe link in those messages or adjusting your account preferences. (See Your Choices and Rights below for more on opting out.) Even if you opt out of marketing, we may still send you important service-related communications (e.g. account notifications, password reset emails, security alerts) as these are necessary for us to provide the Services.