Privacy Policy

This Privacy Policy describes how AJOPAK SOLUTIONS (doing business as AjoPak) (we, us, or our) collects, uses, discloses, and protects personal information when you use our Services.

Services means our public marketing website at ajopak.com and our consumer mobile applications for iOS and Android that link to this policy (AjoPak). We do not offer a customer-facing web application; internal tools we use to operate the business are not covered by this policy.

We are located in Province of Ontario, Canada. We aim to handle personal information in line with Canada's Personal Information Protection and Electronic Documents Act (PIPEDA), where it applies, and applicable provincial law. If you access the Services from outside Canada (for example, Nigeria or elsewhere), additional local privacy laws may also apply. This policy does not limit any rights you may have under those laws.

Questions? Contact us at support@ajopak.com. If you do not agree with this policy, please do not use the Services.

Summary of key points

This summary highlights key topics. Read the full policy below or use the table of contents to jump to a section.

• What personal information do we process? It depends on how you use the Services: your account and contact details, the circle activity you take part in, payout bank details you publish to your circle, identity verification results, photos you choose to attach, push notification tokens, and device and log data. See What information we collect.
• What we do not collect. We do not store images of your identity documents, we never see your card details, and our mobile apps do not use your camera. See What information we collect.
• Do we receive information from third parties? Yes. We work with service providers (for example, hosting, email delivery, analytics, crash reporting) and, when you choose them, authentication partners such as Google and Apple for sign-in on our mobile apps. They may provide us with account-related details according to your settings and their policies. See Third-party services and social logins.
• How do we use information? To provide and improve the Services, communicate with you, secure our systems, comply with law, and for other purposes we describe. See How we use your information.
• Do we share personal information? We share it with service providers who assist us, when required by law, to protect rights and safety, or with your direction. See When we share information.
• Cross-border processing. We and our service providers may process or store personal information in Canada, the United States, and other countries where we or they operate. See Cross-border processing.
• Your rights. Depending on applicable law, you may have rights to access, correct, or delete certain information, withdraw consent where processing is consent-based, or complain to a privacy regulator. See Your privacy rights.
• Deleting your account. You can delete your account in the app, or on our account deletion page if you no longer have it. Some records must be kept for at least 5 years afterwards. See How long we keep information.
• How to exercise rights. Email support@ajopak.com with your request. We may need to verify your identity.

Table of contents

1. What information we collect
2. How we use your information
3. Legal bases and PIPEDA
4. When we share information
5. Cross-border processing
6. Users outside Canada
7. Cookies and similar technologies
8. Third-party services and social logins
9. Savings circles, visibility, and verification
10. How long we keep information
11. Security
12. Your privacy rights
13. Children and minimum age
14. Changes to this policy
15. How to contact us

1. What information we collect

We may collect the following categories of information, depending on how you use the Services:

• Account and identity. Name, email address, phone number, postal address, country, profile photo, and credentials you provide when you register or update your account.
• Authentication data. When you sign in with Google or Apple on our mobile apps, we may receive identifiers and profile information that those services make available to us, subject to your choices and their terms.
• Circle and activity data. Information about savings circles or groups you belong to, roles, schedules, contribution status, payout order, messages or notes you submit in the app, and similar metadata needed to coordinate your group. Other members in the same circle may see information needed for the group to function, as explained in Savings circles, visibility, and verification.
• Payout and payment details.Where you are set to receive a payout, the bank account details you publish to your circle so members can pay you — bank name, account number, account name, routing or sort code, and any Interac or PayPal email address and instructions you add. We also keep records of participation fees and other charges you pay us, including amounts, dates and status. We never see or store your card details.Card payments are entered on our payment processor's own hosted page, which opens in a browser window; we receive only the result of the payment.
• Identity verification.Verification runs on our verification provider's own hosted page, not inside our app. We do not collect or store images of your identity documents.What we keep is the outcome and the details needed to act on it: the provider's reference, the result and confidence, any sanctions or politically-exposed-person screening result, a record that you consented and which notice version you agreed to, and a snapshot of the details checked — your name, date of birth, phone, email, country and national identification number. The identification number is encrypted where we store it.
• Guarantor details you provide.Where a circle requires a guarantor, you may give us that person's name, phone number, email address and their relationship to you. Please provide these only with that person's knowledge, and tell them we hold the details on your behalf.
• Photos you choose to share.Our mobile apps can attach images you pick from your device's photo library — your profile photo, a circle's image, attachments in circle chat, and proof of a payment you have made. We ask for photo library access only at the moment you tap to add an image, and our apps do not use your camera.
• Push notification tokens. If you allow notifications, we store the push token your device issues and the platform it belongs to, so we can send you circle reminders and alerts. You can turn notifications off at any time in your device settings or in the app.
• Device and technical data. Device type, operating system, app version, device identifiers, IP address, diagnostic logs, and similar data used to deliver the Services, troubleshoot, and improve security. This includes crash reports sent to our crash reporting provider when the app stops unexpectedly, and a record of which screens and in-app help you used, so we can tell which parts of the app need work.
• Communications. Content of emails or in-app messages you send to us and records of support requests.
• Website usage. Pages viewed, referring URLs, and similar information collected via cookies or similar technologies on our marketing site (see Cookies).

We collect personal information directly from you, automatically when you use the Services, and from third parties such as authentication providers and service providers as described in this policy.

2. How we use your information

We use personal information to:

• Provide, operate, and improve the Services, including savings circle coordination features;
• Create and manage accounts and authenticate users;
• Communicate with you about the Services, updates, and support;
• Send you push notifications and emails about your circles, such as contribution reminders, payout schedules and security notices;
• Verify your identity, screen against sanctions lists, and meet anti-money-laundering obligations;
• Take payment for our fees and record what you have paid;
• Monitor and help protect the security and integrity of our systems and users;
• Detect, prevent, and address fraud, abuse, or technical issues;
• Comply with applicable legal obligations and respond to lawful requests;
• Exercise or defend legal claims; and
• Carry out other purposes we disclose to you and, where required, with your consent.

3. Legal bases and PIPEDA

Where PIPEDA applies, we handle personal information in line with its fair information principles, including: accountability; identifying purposes; consent (express or implied, as appropriate); limiting collection, use, and disclosure; accuracy; safeguards; openness; individual access; and giving individuals a meaningful way to challenge our compliance.

If you are in Canada and believe we have not met our obligations, you may file a complaint with the Office of the Privacy Commissioner of Canada, subject to their processes.

4. When we share information

We may disclose personal information:

• Service providers.To vendors who assist us: identity verification and sanctions screening, payment processing, cloud hosting and file storage, email delivery, push notification delivery, crash reporting, and customer support tools. They may only use the information as instructed by us for those purposes, subject to appropriate contractual protections where feasible. We give each provider only what that service needs — for example, our payment processor receives the payout account details needed to send a payment, and our verification provider receives the details needed to run the check.
• Authentication partners. When you use Google or Apple sign-in, information is shared between you, us, and that provider as needed to complete sign-in, as described in Third-party services and social logins.
• Legal and safety. When we believe disclosure is required by law, legal process, or government request; to enforce our terms; to protect our rights, property, or safety or that of our users or others; or to detect or prevent fraud or abuse.
• Business transfers. In connection with a merger, acquisition, financing, reorganization, or sale of assets, subject to appropriate safeguards.
• With your direction. When you ask us to share information or otherwise consent.

We do not sell your personal information as a product in the traditional sense. We do not use personal information for third-party cross-context behavioural advertising unless we implement that in the future and update this policy.

5. Cross-border processing

We and our service providers may process, store, or access personal information in Canada, the United States, and other countries where we or they maintain facilities or personnel. Those jurisdictions may have different data protection laws than your home country. Where required, we use appropriate safeguards (such as contractual terms) for cross-border transfers, in addition to this notice.

6. Users outside Canada

The Services may be accessed from many countries. If you are located outside Canada (for example, in Nigeria), local privacy laws may also apply to our processing of your information. If you have questions about how local law applies, contact us at support@ajopak.com or consult qualified counsel in your jurisdiction.

7. Cookies and similar technologies

Our marketing website may use cookies, pixels, or similar technologies to remember preferences, measure traffic, and improve the site. You can control cookies through your browser settings. Some features may not work if you disable cookies. If you use our cookie banner, we may store your preference locally in your browser (for example in localStorage) so we remember your choice. For more detail, see our Cookie Policy.

8. Third-party services and social logins

The Services rely on third-party services that have their own privacy policies. Their processing is governed by those policies. Examples include:

• Google Sign-In — see Google's Privacy Policy.
• Sign in with Apple — see Apple's Privacy Policy.
• Smile Identity — our identity verification and sanctions screening provider. Where verification is required, the check runs on a page hosted by them and is governed by their privacy policy.
• Paystack — our payment processor. Card payments are entered on their hosted checkout page and are governed by their privacy policy; we do not receive your card details.
• Infrastructure and operations — for example, cloud hosting and file storage, email delivery, push notification delivery, analytics, and crash reporting, as we implement them.

When you choose to sign in with Google or Apple on our mobile apps, we receive information that those services make available to apps like ours (for example, a stable identifier and, depending on your settings, name or email). Your use of Google or Apple sign-in is also subject to their terms.

9. Savings circles, visibility, and verification

AjoPak is a coordination and visibility tool for trusted groups. We are not a bank, do not take custody of your funds as a financial institution in that capacity, and do not provide legal, tax, or investment advice. How money moves between members depends on your group's arrangements.

Information about circle membership, contributions, payouts, and related activity may be visible to other members in the same circle so the group can stay aligned. It is not intended to be published on the open web. Group rules and agreements remain between members; our software reflects what your group sets up in the product.

Some circles or organizations may require identity verification, and creating or administering a circle may require a higher level of verification than joining one. Where verification is enabled, the check runs on our provider's hosted page and we keep the result rather than your documents, as described in What we collect. Your verification details are not shown to other members of your circle.

10. How long we keep information

We retain personal information only as long as necessary for the purposes described in this policy, including to provide the Services, comply with legal obligations, resolve disputes, and enforce our agreements. Retention periods vary depending on the type of information and context.

When you delete your account, we erase your sign-in details, name, phone number, address, profile photo, payout bank details, sessions, push notification tokens, notifications, notification settings and your in-app help usage, and we ask our payment processor to remove its copy of your payout details.

We are required to keep certain records for fraud prevention and regulatory compliance, and these are retained for at least 5 years after deletion. They remain linked to an anonymised account record rather than to your name. They are:

• Identity verification records, including sanctions screening results and consent records;
• Contribution, payment receipt, payout, billing and circle ledger records;
• Your AjoPak Score history and any red alerts;
• Audit logs of security-relevant actions;
• Messages you sent in circle chat, which remain visible to that circle;
• Guarantor records, which include the name, phone number and email address of a guarantor you named or a circle named for you; and
• Payout account details published inside a completed round, which stay with that round's records. These are encrypted where we store them.

We say at least 5 years deliberately: we do not currently run an automatic purge, so these records may be kept longer. Our account deletion page sets out the same lists, and you can ask us about a specific record at any time.

11. Security

We use technical and organizational measures designed to protect personal information. No method of transmission or storage is completely secure; we cannot guarantee absolute security.

12. Your privacy rights

Depending on applicable law, you may have the right to request access to, correction of, or deletion of certain personal information we hold; to withdraw consent where processing is based on consent; to object to or restrict certain processing; or to lodge a complaint with a supervisory authority.

You can delete your account and the personal data that goes with it at any time, in the app under Settings, or on our account deletion page. That page lists what we erase and what we are required to keep.

To exercise these rights, email support@ajopak.com. We will respond in line with applicable law. We may need to verify your identity before fulfilling certain requests.

13. Children and minimum age

The Services are intended for users who are at least 18 years old. We do not knowingly collect personal information from anyone under 18. If you believe we have collected information from someone under 18, contact us at support@ajopak.com and we will take appropriate steps.

14. Changes to this policy

We may update this Privacy Policy from time to time. We will post the updated version on this page and revise the "Last updated" date. If changes are material, we may provide additional notice (for example, in-app or by email) where appropriate.

15. How to contact us

Operator / data controller
AJOPAK SOLUTIONS (doing business as AjoPak)
21 Richgrove Drive, Unit 603 Etobicoke, Ontario M9R 2L2 Canada

Email: support@ajopak.com

For other ways to reach us, see our Contact page.

Last updated: September 23, 2026