This policy explains how Crownbridge Global Limited trading as LEEPAPAY handles personal information connected with its public website and payment services.
1. Who we are and scope
Crownbridge Global Limited is incorporated in Kenya under registration number PVT-L51DKK92. Our registered address is Krishna Centre, Woodvale Grove, Westlands, Nairobi, Kenya, and our published business address is Unit E05, 3rd Floor, Krishna Centre, Woodvale Grove, Westlands, Nairobi, Kenya. For privacy questions, contact risk.compliance@leepapay.com.
This policy covers website visitors, prospective merchants, merchant representatives, directors, shareholders, ultimate beneficial owners and authorised persons submitted during onboarding, people communicating with us, and payer or customer information processed where necessary in connection with payment transactions. A merchant agreement may contain additional information for a particular service.
2. Information we handle
Depending on the relationship and service, we may handle:
- names, email addresses, telephone numbers and other contact details;
- website contact-form submissions, support requests and correspondence;
- merchant company, registration, business address and representative information;
- KYB/KYC, identification, compliance and due-diligence information about directors, shareholders, ultimate beneficial owners and authorised persons;
- merchant banking and settlement information;
- transaction identifiers, amounts, currencies, payment methods, statuses, timestamps, merchant and MID details, provider and reconciliation references, and payer or customer identifiers needed for processing;
- IP addresses, browser and device information, and API, application, security and system logs; and
- fraud, compliance and risk-monitoring information.
We obtain information from you, merchants and their representatives, use of our website and services, and parties involved in payment processing, verification or compliance.
3. Payment information
We may receive or process information necessary to initiate, route, monitor, reconcile and settle payments. Depending on the payment method and integration, some payment information is processed directly by banks, mobile-money operators, acquirers, processors or other payment-service providers rather than necessarily being stored by LEEPAPAY.
4. Purposes and legal grounds
We use personal information to answer enquiries; assess and onboard merchants; provide, administer and support services; process and reconcile transactions; secure systems; detect and investigate fraud or misuse; comply with legal, regulatory, AML/CFT, tax and accounting requirements; handle complaints and disputes; and establish, exercise or defend legal claims.
Depending on the activity, processing may be necessary to take steps before or perform a contract, comply with a legal obligation, pursue a legitimate interest that is not overridden by your rights, or rely on consent where consent is required. General website enquiries are voluntary. Without contact details or enough information about an enquiry, we may not be able to respond. Required onboarding or transaction information may be necessary to provide a service or meet legal duties; without it, onboarding or processing may not be possible.
5. Sharing with others
We may make information available, to the extent reasonably required, to cloud and infrastructure providers; email and communications providers; payment processors and acquiring institutions; banks, mobile-network and mobile-money operators, switches and settlement partners; identity-verification and compliance providers; security and fraud-prevention providers; professional advisers and auditors; and regulators or other public authorities where disclosure is legally required. Only the categories relevant to an activity or transaction will be involved.
6. International transfers
Personal information may be processed outside Kenya where our infrastructure, communications, payment, compliance or other service providers operate internationally. We apply the conditions and safeguards required by applicable data-protection law for such processing and transfers.
7. Retention
We retain information for as long as reasonably necessary for its purpose and as required for legal, regulatory, AML/CFT, accounting, tax, contractual, reconciliation, fraud-prevention, audit, dispute-resolution and legal-claims purposes. Particular merchant, transaction, compliance or financial records may be kept longer where an applicable law, regulator, provider or contract requires it. When information is no longer needed, we delete, anonymise or otherwise dispose of it in accordance with our retention procedures.
8. Security
We use reasonable and appropriate technical and organisational measures intended to protect personal information against unauthorised access, disclosure, alteration, loss or destruction. No method of transmission or storage provides absolute security.
9. Cookies and website technology
At the effective date of this policy, the public LEEPAPAY website does not use analytics or advertising pixels or non-essential tracking cookies. The website uses ordinary browser and hosting technologies to display pages, process enquiries and maintain security. Our hosting infrastructure may record IP addresses, browser information and technical logs for operation and security. If non-essential tracking is introduced later, we will update this notice and provide any choices required by law.
10. Your rights
Subject to applicable law, you may request information about our processing, access to your personal information, correction or deletion, and object to or ask for restriction of processing. Where consent is the legal basis, you may withdraw it. Some requests may be limited by legal retention duties or other lawful grounds. Contact risk.compliance@leepapay.com; we may verify your identity before fulfilling a request. You may also raise a concern with Kenya's Office of the Data Protection Commissioner.
11. Updates and contact
We may update this policy as our services or legal requirements change. The current version and effective date will appear on this page. For privacy requests, contact risk.compliance@leepapay.com or write to Crownbridge Global Limited trading as LEEPAPAY, Unit E05, 3rd Floor, Krishna Centre, Woodvale Grove, Westlands, Nairobi, Kenya.