PRIVACY POLICY — AERMINT (PaybyAir Systems Limited)

This Privacy Policy describes how PaybyAir Systems Limited; trading as “AerMint”, (“we”, “us”, or “our”) collects, uses, discloses and protects personal data when you access or use the AerMint mobile application and related services (“App” or “Services”) globally.

By downloading, installing or using the App you consent to the collection, use and transfer of your data as described here.

Data controller: PaybyAir Systems Limited, registered at 39 Bourdillion Road Ikoyi, Lagos State Nigeria.

Privacy contact: privacy@paybyair.com. Data protection officer: Tolu Odueke. tolulope@paybyair.com

Identity & account: name, email, phone, date of birth, national ID number.

Transaction & financial: airtime top‑up records, payment identifiers, transaction amounts, currency, beneficiary details, settlement records.

Verification & compliance: identity documents, proof of address, biometric or photographic data where required for KYC/AML.

Device & technical: device identifiers, OS version, app version, IP address, log files, crash reports.

Location: country/region derived from IP or device settings; precise geolocation only with explicit opt‑in.

Communications: messages to support, in‑app chats, feedback.

Analytics & cookies: usage metrics, cookies and SDK data.

Provide, operate and maintain the App; process and settle transactions.

Identity verification, KYC/AML, sanctions screening and fraud prevention.

Compliance with legal, tax and regulatory obligations.

Service improvement, analytics, product development and security monitoring.

Customer support, notifications and, where consented, marketing communications.

Enabling cross‑border settlement and FX operations.

Performance of contract (to deliver Services).

Compliance with legal obligations (KYC/AML, tax).

Legitimate interests (fraud prevention, service improvement), balanced against users’ rights.

Consent (for marketing, precise location and optional features).

We share data with: payment processors, banks, Telcos, identity verification providers, cloud hosts, analytics providers, professional advisors and regulators where required.

Data may be transferred to jurisdictions outside your country. We implement safeguards (e.g., Standard Contractual Clauses, Binding Corporate Rules) or rely on adequacy decisions, where applicable.

Data is retained as necessary to provide Services, meet legal obligations, resolve disputes and enforce agreements. Retention durations vary by data type and jurisdiction.

We apply industry standard safeguards, including encryption in transit, access controls, logging, incident response and periodic security reviews. Absolute security cannot be guaranteed.

Subject to local law, you may request access, rectification, deletion, portability, restriction of processing and object to processing. You may withdraw consent for marketing at any time.

To exercise rights, contact privacy@paybyair.com. We may require identity verification.

The App is not intended for persons below the minimum legal age in their jurisdiction. We do not knowingly collect personal data from children without parental consent.

The App may integrate third‑party services or link externally. Those third parties have separate privacy practices for which we are not responsible.

Material changes will be notified via the App or email. Continued use after changes constitutes acceptance.

You may lodge complaints with your local data protection authority if unsatisfied with our response.

privacy@paybyair.com