Effective Date: October 23, 2025
Scope: This Privacy Policy applies to the services of Paydoly Inc., a company registered in Atlanta, GA, USA, and Paydoly Dominicana SRL, registered in the Dominican Republic (collectively referred to as “Paydoly,” “we,” “us,” or “our”). It governs how we collect, use, disclose, and protect personal information of all our users, whether you are located in the United States, the Dominican Republic, or elsewhere. Paydoly is committed to handling personal data in accordance with applicable U.S. data protection and privacy laws (including federal law and state laws like the California Consumer Privacy Act (CCPA)) and we voluntarily apply these high standards to all users, including those in the Dominican Republic. In jurisdictions that lack specific privacy regulations (such as the D.R.), we still provide the protections and rights described in this Policy to ensure consistency and transparency.
By using Paydoly’s services, you acknowledge that you have read and understood this Privacy Policy. If you do not agree with our practices, please do not use our services. We may update this Policy from time to time (see Section 9 on changes).
Paydoly must collect certain information about you to provide our digital payment services securely and effectively. We limit our collection to what is relevant and necessary. The categories of data we collect include:
Personal Information: This is information that identifies you as an individual or relates to an identifiable person. It includes: your full name, contact details (email address, telephone number, mailing address), date of birth, social security number or other government‑issued identification number (such as a passport or national ID number), nationality and country of residence, and any other information you provide on identity verification documents. For example, when you sign up, we ask for your name, address, and may collect a copy of your ID or your social security number for Know Your Customer purposes. Personal information also encompasses account credentials (username, password) and any photograph or profile picture you might upload to our app.
Transactional Data: This refers to information about the financial transactions you conduct through Paydoly. It includes details such as the amounts you transfer or receive, the currency used, the dates and times of transactions, the recipients or senders (which may include identifiers like email or phone number if you’re sending to another user), and payment methods used (e.g. which bank account or card is linked, though Note: Paydoly does not store full bank account numbers or card numbers on our servers except possibly the last 4 digits or a token, since such sensitive financial info is handled by our payment processor). We also keep records of transaction history including bills paid or mobile top‑ups etc., any fees charged, and reference notes or descriptions you add to payments. Transactional data may also include information about device or location from which the transaction was initiated, as part of the log.
Behavioral Data: We collect data on how you interact with our services, essentially usage information. This can include: your app or website usage patterns (such as features you use, pages or screens you visit, the time spent on certain functions), your clicks, navigation paths, and how you respond to in‑app prompts. It also includes logs of your communications with us, for instance, if you contact customer support or respond to surveys, we will have records of that correspondence. Behavioral data helps us understand user engagement and improve our services. Additionally, if we send marketing emails or notifications, we may collect data on whether you opened them or clicked links, to gauge interest (you have controls over marketing; see Section 5 on opt‑out).
Biometric Data: In certain cases, we may collect biometric identifiers or information. Specifically, as part of identity verification (KYC) processes, you might be asked to provide a selfie photograph or a live facial scan, which we compare to your government ID (this is a form of biometric verification). We treat this biometric data with a high level of security and confidentiality, and we only use it to verify your identity and prevent fraud. Another form of biometric data could be voice if you call our support and we use voice identification, though currently we do not employ voice biometrics. We do not collect fingerprints or DNA or such; our biometric focus is on photographs for identity verification. Biometric information is considered sensitive personal data, and we will obtain your consent where required by law before collecting it. (For example, some U.S. state laws like Illinois’s BIPA require consent for biometric capture; we will comply with applicable requirements.)
Device and Technical Data: When you use Paydoly, we collect information about the devices and networks you use to access our services. This includes:
We obtain most of this information directly from you (e.g. information you input during registration or transactions). Some information is collected automatically through your use of the service (like device and usage data). In addition, we may receive information about you from third parties such as verification services and business partners: for example, Stripe (our KYC provider) may return a verification result or risk score about you after checking your provided identity details; or if you link a bank account, we might use a service that provides us confirmation of account ownership. If we expand to use credit bureaus or fraud databases, we might collect relevant info from them too (such as flags or identity verification questions). We treat any such third‑party‑sourced data according to this Policy as well.
We use the collected information to operate, provide, improve, and protect Paydoly’s services. The following are the purposes for which Paydoly processes your data (with examples):
To Provide Services: First and foremost, we use personal and transactional data to create and manage your account, to process your payments and transfers, and to facilitate any other features you use. For example, we use your provided information to verify your identity when you sign up, enabling you to send money to others. We use recipient data you provide (like a friend’s email or phone number) to route payments to that person. If you set up recurring transactions, we use your stored data to execute those as instructed. Essentially, without your info, we cannot perform the contract of providing you Paydoly services.
Verification and Security: We use personal and biometric data to verify your identity and fulfill our legal obligations for KYC/AML (Know Your Customer/Anti‑Money Laundering). Your government ID and selfie are used to confirm you are who you claim, often through our third‑party verification provider (Stripe). We also use information to authenticate your access to the account (for instance, we may use your phone number or email to send verification codes, or your device info to recognize trusted devices). Device and network data, as well as behavioral signals, are used for fraud prevention and security monitoring. For example, if a login occurs from a new device or location, we might flag the account for verification. We may also employ automated systems to analyze transactions and usage for suspicious patterns to protect our users and the platform from fraud, hacking, or money laundering.
Compliance with Legal Obligations: There are various laws requiring us to collect and use certain data. For example, financial regulations require us to maintain records of transactions and identity information (as described in our KYC/AML Policy). We will use your data to comply with court orders, subpoenas, lawful requests by government authorities (including tax reporting requirements or sanctions screening), and to satisfy anti money laundering controls (monitoring transactions and possibly reporting to regulators if necessary). If you are a user in the Dominican Republic, note that we apply U.S. standards here too, meaning we treat your data with confidentiality but will use it to fulfill any U.S. or Dominican reporting obligation where applicable.
Service Communications: We use contact information to communicate with you about your account and transactions. This includes sending you confirmations of transactions, alerts about account activity (like login alerts or password change notifications), and notices about updates to our terms or policies. These service‑related communications are necessary for us to keep you informed of important information regarding the services and your security; you cannot generally opt out of these essential communications without closing your account.
Customer Support: If you reach out for support, we will use your information to assist you. This might involve reviewing your account details, transaction history, or technical info (like app version, device) to diagnose issues. We keep records of support inquiries and our responses.
Improvement and Analytics: We use usage and device data to analyze how our services are used and to improve performance and develop new features. For instance, we might analyze which features are most popular or where users encounter errors, so we can optimize those areas. We may use aggregated data (which does not identify individuals) to understand trends and user demographics. This helps us enhance our user interface, plan new services, and make informed business decisions. We may also derive insights from transactional patterns (in aggregated form) to improve our fraud detection algorithms or to suggest features.
Marketing and Optional Communications: With your consent or as permitted by law, we may use your contact info and usage data to send promotional content about our services or new features. For example, we might send an email newsletter with tips or special offers, or suggest referral programs that you could benefit from. We may also tailor our marketing. For instance, if we know you frequently use Paydoly for certain types of payments, we might highlight a related feature. Important: If we ever decide to use third‑party analytics or advertising networks (as noted later, we currently do not, but may in future), information like cookies and device identifiers might be used to personalize ads or measure effectiveness. You will have control as described in Section 5 to opt in or out of marketing.
Biometric Use: If we collect biometric data (like your facial scan), it will be used solely for verification and security purposes. We do not use biometric information for any advertising or unrelated profiling. For example, the selfie you provide is used in an automated way to compare against your ID photo for identity proofing. After that, we retain biometric identifiers only as long as needed for that purpose or as required by law (see data retention below). In some jurisdictions, we may be required to get separate consent for biometrics and to provide a means for you to request deletion of biometric data, which we will honor.
Device Data Use: Technical device and log data are used for debugging, protecting our systems, and ensuring compatibility. For instance, knowledge of what app versions or devices people use helps us test and ensure our service works well across them. IP addresses are used to provide more relevant service (like language or regional settings), and to guard against fraud (e.g., blocking an IP that is performing attacks).
We will not use your personal information for purposes that are materially different from the above without notifying you and obtaining your consent if required. We do not engage in “selling” of personal information as defined under CCPA (we don’t provide your data to third parties for money or their own marketing). Any use of your data for new purposes, especially if unrelated to the original purpose, will be communicated to you through an updated privacy notice or a consent request.
(Currently, Paydoly does not use extensive third‑party analytics or advertising cookies. However, for completeness and future readiness, we address how we might handle cookies.)
Cookies: Cookies are small text files placed on your device that help websites function and gather information. Our website may use cookies and similar tracking technologies (like web beacons or pixels) primarily for functionality and security. For example, we might use a cookie to keep you logged in as you navigate our site, or to remember your language preferences. We may also use cookies to collect basic web traffic data via in‑house analytics (like counting visits, referring URLs, etc.). These are typically first‑party cookies (set by Paydoly).
At present, we do not employ third‑party analytics services (such as Google Analytics) on our website, nor do we use advertising networks that track you across sites. This means we are not currently setting third‑party cookies for marketing or data sharing purposes. In the future, if we decide to add an analytics tool or any cookie that collects personal data beyond our own uses, we will update this Policy and provide notice or opt‑in prompts as required. For instance, if we add Google Analytics to help analyze website use, we would then inform you and allow opt‑out as needed (Google Analytics typically can be disabled by browser settings or opting out).
Your Choices for Cookies: Most web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies or alert you when cookies are being sent. However, please note that if you disable cookies entirely, some features of our website may not function properly (like staying logged in). For essential cookies (that ensure security or basic functionality), our site may not have an option to disable those without impacting service.
On our mobile app, cookies are not typically used in the same way, but there are analogous technologies (like device IDs). If we ever implement analytic tracking in the app, we will provide an in‑app settings option for you to limit that tracking to the extent possible.
In summary, at this time we have a minimal usage of cookies, focused on necessary operation. As our use of any tracking technologies evolves, we will maintain transparency and user control.
Paydoly understands that your information is important and we are not in the business of selling your personal data to others. We share information only in the following circumstances:
Rest assured, we do not sell your personal data to third parties for their own marketing or profit. We do not share your information with advertisers or data brokers. Any sharing we do is aimed at serving you, running our business, and fulfilling legal duties, as outlined above.
We believe in empowering our users with control over their personal data. Depending on your jurisdiction and our internal policies, you may have some or all of the following rights regarding your personal information:
To exercise any of your rights, please contact us via the channels provided in Section 9 (Contact Information). We may need to verify your identity before fulfilling certain requests (for example, we might ask you to confirm logged‑in control of your account or provide identifying info). This is to ensure we don’t release or modify data at the request of someone other than the account holder. We aim to respond to requests as soon as reasonably possible, generally within 30 days. If we need more time (up to 45 days more, for example, due to complexity), we will inform you of the reason and extension.
Paydoly operates in both the United States and the Dominican Republic, and we may process data in either or both countries, as well as potentially other locations where our service providers have servers (e.g., cloud infrastructure may be global). By using Paydoly, you acknowledge that your information may be transferred to or stored on servers located in a country different from your own. Specifically:
Between U.S. and D.R.: Data of Dominican users will likely be stored on infrastructure in the United States (as our primary data center is in the U.S.), and data of U.S. users may be accessed by our Dominican Republic office for customer support or operations. We ensure that such cross‑border data flows happen securely and lawfully. Even though the Dominican Republic currently may not have an equivalent to, say, the EU’s GDPR restrictions on data export, we treat transfers from D.R. to the U.S. with the same caution as if such rules existed. We consider the U.S. privacy protections as the baseline and apply them to all data. In practice, this means Dominican user data receives the same level of protection under our internal policies as U.S. user data does.
Legal Adequacy and Safeguards: The U.S. and D.R. do not have a special adequacy arrangement between them (like the EU has with some countries), but since we are one company operating in both, we have put contractual and operational safeguards in place. All internal transfers are governed by data protection agreements binding our staff and any contractors to protect the data. If we ever engage a service provider in a third country, we will ensure that the provider has robust security certifications or contractual clauses (for instance, if any data were transferred from the U.S. or D.R. to the European Union or vice versa, we’d use standard contractual clauses or similar, but currently, our main transfers are US ↔ DR).
Other International Considerations: If you are accessing Paydoly from outside the U.S. or D.R. (for instance, you’re traveling or you have a different nationality), be aware that your information will still be processed according to this Policy, in the jurisdictions mentioned. If we detect certain country‑specific requirements (for example, if we began serving users in the EU, we would adjust our practices to comply with GDPR), we will comply accordingly. Right now, our focus is US and DR users, to whom we apply U.S. standards across the board.
Government Access: Different countries have different laws about government surveillance and access to data. Paydoly will handle government requests for data carefully, as described in Section 4, and under guidance of our legal counsel, to ensure any cross‑border disclosures are properly handled. We strive to be transparent with users about government requests, unless legally restricted from doing so.
By maintaining robust security measures (next section) and contractual obligations, we aim to protect your data no matter where it is physically located. Our application of U.S. privacy best practices to all data means that even if the Dominican Republic might not require certain protections, we voluntarily implement them. For example, we treat all personal data as if laws like CCPA (and even principles of GDPR regarding security and user rights) apply.
If you have questions about our international data handling, you can reach out to us (Section 9), and we’ll be happy to provide further information.
Protecting your personal and financial information is a top priority for Paydoly. We implement a variety of administrative, technical, and physical security measures designed to safeguard your data against loss, theft, misuse, unauthorized access, disclosure, alteration, and destruction. Here are key aspects of our security program:
Our comprehensive approach to security is aligned with both U.S. federal guidelines and industry best practices. We continuously evaluate new security technologies and threats and update our safeguards accordingly. For more details on our security practices, you can contact us, and we may provide a summary of our measures (within the bounds of keeping our methods secure).
We retain personal information for as long as necessary to fulfill the purposes outlined in this Policy, while also adhering to applicable laws and regulations. Because we are a financial services provider, certain data must be kept for minimum retention periods to comply with legal obligations (e.g., anti money laundering record retention, tax laws, etc.). Below is an overview of our retention practices:
When we no longer have a legitimate need or legal obligation to retain your personal information, we will dispose of it in a secure manner. This could involve irreversible anonymization (converting data to a form that cannot be linked to you) or complete deletion from our systems. We also take care to remove data from any third parties that were processing it on our behalf, once it’s no longer needed.
Please note that due to the way certain technologies work, there might be delays in deleting residual copies (for example, info cached in systems or stored in intermediate data stores). We aim to ensure deletion requests and retention expirations are fully processed across all environments in a reasonable time frame.
We may update this Privacy Policy from time to time to reflect changes in our practices, technologies, legal requirements, and other factors. If we make a significant change (one that materially affects how your personal data is handled), we will notify you in advance through appropriate means. This might include:
The “Effective Date” at the top of this Policy will be updated to the date of the latest revision. We encourage you to review this Policy periodically to stay informed about how we are protecting your information.
If you continue to use Paydoly’s services after a revised Privacy Policy has become effective, it means you accept the revised terms. If you do not agree with the changes, you should discontinue use of the services and may close your account (as you always retain the right to do).
If you have any questions, concerns, or requests regarding this Privacy Policy or how your data is handled, please do not hesitate to contact us. We are here to help and clarify our practices. You can reach Paydoly’s privacy team at:
Email: privacy@paydoly.com Address: Paydoly Inc., 1201 W Peachtree St. NW Ste 2367, Atlanta, GA 30309, USA (Attn: Paydoly Privacy) and/or Paydoly Dominicana SRL, Av. Núñez de Cáceres No. 256, El Millón, Santo Domingo, National District., Dominican Republic.
We will respond to your inquiries as soon as possible, generally within 30 days. If you need to access, correct, or delete your data, or opt out of any services, contacting us through the above channels is the best way to exercise those rights.
Additional Resources: For U.S. users, you can learn more about consumer privacy rights from resources like the Federal Trade Commission (FTC) website. California residents can visit the California Attorney General’s site for information on the CCPA. While these external resources are not directly related to Paydoly, they can provide helpful context on privacy laws and your rights.
For Dominican Republic users, since local privacy law is still developing, you may consult the Dominican Institute of Telecommunications (INDOTEL) or any agency handling electronic commerce and data protection for guidance, though we reiterate that Paydoly is applying robust U.S.‑level privacy protections for your benefit.
By using our services, you entrust us with your personal information, and we take that responsibility very seriously. This Privacy Policy is intended to inform you in a clear and comprehensive manner. Thank you for reading it.