Legal & Sharia Governance Note: Wadaag Pay is an official digital banking product owned and operated by Wadaag Bank, headquartered in Hargeisa, Somaliland. As a Sharia-compliant financial institution, Wadaag Bank operates under strict ethical banking principles, Central Bank regulatory oversight, Anti-Money Laundering (AML), and Know Your Customer (KYC) requirements. Please review this policy carefully before activating your account.
Wadaag Bank is a Sharia-compliant Islamic financial institution committed to protecting your privacy and handling your personal information in accordance with applicable laws, regulatory requirements, and the principles of Islamic banking. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you use our mobile application (Wadaag Pay) and digital banking channels (collectively, the "Services").
By downloading, registering with, or utilizing the Wadaag Pay mobile app, you acknowledge that you have read, understood, and agreed to the data practices described in this Privacy Policy.
1. Information We Collect
To deliver secure mobile payment services, maintain Sharia-compliant account integrity, fulfill banking regulations, and prevent financial fraud, we collect the following categories of information:
- Personal Identity Information: Your full legal name, national identity number, passport details, date of birth, government-issued photo ID, email address, mobile phone number, and physical residential address collected during onboarding or synchronized via your Wadaag Bank profile.
- Financial & Transactional Data: Linked Wadaag Bank account numbers, digital wallet balances, real-time Islamic financial transaction records (deposits, transfers, withdrawals, merchant payments, bill payments), card credentials, and saved beneficiary payment details.
- Device Technical Data: Internet Protocol (IP) address, hardware model, unique device identifiers (e.g., IMEI, UUID, Android ID, or IDFA), operating system version, mobile network operator, and app stability crash report analytics.
- Biometric Data (Local Authentication): Where enabled on your mobile device (such as fingerprint or facial recognition), the app utilizes native hardware frameworks for secure login and transaction sign-offs. We never access, transmit, or store raw biometric metadata on external servers; verification is handled entirely on your local device.
2. Mobile Application Permissions Requested
To enable core functional operations, Wadaag Pay requests access to specific hardware capabilities on your mobile device. You can manage or revoke these permissions via your device settings at any time:
- Camera Access: Used exclusively to scan QR codes for peer-to-peer transfers or merchant payments, and to capture identity documents during customer verification (KYC).
- Push Notifications: Used to send essential transaction receipts, security alerts, login verification codes (MFA), and system status updates.
- Storage / Files Access: Utilized to temporarily export and save downloadable payment receipts, account statements, and official tax or financial documents.
3. How We Use Your Information
We process your personal and operational data exclusively for legitimate banking, ethical security, and regulatory purposes, including:
- Core Service Provisioning: Executing real-time transfers, utility payments, wallet top-ups, account balance updates, and continuous synchronization with Wadaag Bank systems.
- Fraud Prevention & Ethical Security: Monitoring anomalous transactions, running automated risk verification algorithms, detecting unauthorized access, and securing financial assets against cyber threats in compliance with Islamic financial integrity.
- Regulatory & Sharia Compliance: Fulfilling mandatory statutory obligations under Central Bank guidelines, Know Your Customer (KYC) standards, Anti-Money Laundering (AML) monitoring, and Counter-Terrorism Financing (CTF) oversight.
- Customer Care & Dispute Resolution: Resolving payment claims, fixing technical bugs, and responding to customer support inquiries.
- App Optimization: Analyzing anonymized system metrics to improve application performance, responsiveness, and uptime.
4. Information Sharing & Disclosure
We do not sell, rent, trade, or lease your personal data to third parties for marketing purposes. Data sharing occurs strictly in the following scenarios:
- Wadaag Bank Infrastructure: As an official product of Wadaag Bank, application data is integrated into Wadaag Bank's core banking architecture in Hargeisa, Somaliland, to fulfill financial transactions.
- Authorized Service Providers: We engage verified technical vendors (such as SMS network providers, identity verification platforms, payment gateways, and core infrastructure hosts) bound by strict contractual confidentiality and data security obligations.
- Legal Enforcement & Judicial Orders: Data may be disclosed if mandated by valid court orders, financial regulatory authorities, or official law enforcement investigations under applicable laws.
5. Data Security
We apply bank-grade security protocols to protect your personal and financial information against unauthorized access, destruction, loss, or alteration:
- End-to-end data encryption in transit using Transport Layer Security (TLS 1.3 / SSL).
- Advanced AES-256 bit encryption for sensitive user data stored at rest.
- Multi-Factor Authentication (MFA) requirements for account sign-ins and high-value transfers.
- Continuous vulnerability assessments, automated fraud monitoring, and strict internal access controls.
6. Data Retention and Account Deletion
We retain your personal profile and historical transaction data for as long as your Wadaag Pay account remains active, or as required by applicable banking regulations (which enforce mandatory retention periods post-account closure for audit and forensic purposes).
Account Deletion Requests: You may request account closure and personal data deletion at any time via the Wadaag Pay app settings or by contacting customer support. Upon receiving your request, non-statutory data will be deleted, while required transaction logs will be archived in compliance with financial retention laws.
7. Your Rights
Depending on your location, you may have the following rights regarding your personal information:
- Access: Request access to the personal information we hold about you.
- Correction: Request correction of inaccurate or incomplete information.
- Deletion: Request deletion of your personal information (subject to legal and business requirements).
- Portability: Request transfer of your information to another service provider.
- Objection: Object to processing of your personal information.
- Restriction: Request restriction of processing of your personal information.
- Withdraw Consent: Withdraw consent for processing based on consent.
To exercise these rights, please contact us using the information provided below.
8. Children's Privacy
Our Services are not intended for individuals under the age of 18. We do not knowingly collect personal information from children. If we become aware that we have collected information from a child under 18, we will take steps to delete such information immediately.
9. Policy Amendments
Wadaag Bank reserves the right to update this Privacy Policy to reflect technical enhancements, statutory changes, or operational adjustments. Users will be notified of material changes through app notices or email updates. Continued use of Wadaag Pay following an update constitutes acceptance of the revised terms.
10. Contact Us
For questions, formal privacy inquiries, or to exercise your rights regarding your personal information, please contact our central compliance department:
