SmartPay Privacy Policy

SmartPay (hereinafter referred to as “SmartPay”, “Company”, “we”, “us”, or “our”) operates the SmartPay Web application,Mobile application, website, POS integrations, APIs, and related digital platforms (collectively, the “Platform”).

This Privacy Policy explains how we collect, use, process, store, and disclose your personal information when you access or use SmartPay’s bill payment, digital payment facilitation, POS-based financial services, and related offerings (collectively, the “Services”).

We are committed to protecting your privacy and ensuring that your personal data is handled securely and transparently. Please read this SmartPay Privacy Policy before using the Platform or submitting any personal information to SmartPay.

1. Acceptance

By using SmartPay services, you consent to lawful collection, processing, and sharing of your information as described herein.

2. Changes to This Privacy Policy

We may update this Privacy Policy from time to time due to legal, regulatory, or operational requirements.

Updated versions will be posted on the Platform and become effective immediately upon publication. Where required, we may notify you via in-app notification, SMS, or email.

4. Information We May Collect

We collect information to provide secure, reliable, and efficient bill payment and financial facilitation services.

  • Consumer Information may include Full Name, CNIC, Mobile Number, Email, Address etc
  • Billing Data
  • Payment/Transactions details (masked card details, bank references, wallet IDs, Payment channel used, Merchant/biller details)
  • Device and IP information
  • KYC documentation (where required)

This helps us:

  • Process transactions
  • Generate settlement reports
  • Resolve disputes
  • Comply with regulatory requirements

We may receive this information from third parties, such as mobile wallet operators, financial institutions, credit bureaus, duly licensed lenders, other users, partners (including ad partners, analytics providers, search information providers), or our affiliated companies or if you use any of the other websites/apps we operate or the other Services we provide.
We may receive personal information about you from third parties that are engaged by us to assist with providing verification services and conducting suitable money laundering and KYC and AML (anti-money laundering) checks on users of the Platform. This may include your name, email address, company details and contact information.
If you choose to participate in reviewing or rating the Services on the Platform, we may receive personal information about you from third parties that work with us to conduct reviews into our Services and/or rate us. Subject to your consent, we may collect your information and activity from payment providers, advertising networks, analytics providers, search information providers and social media platforms. We may collect social media information you use to log in and interact with our Platform, as long as you agree to share such information with us.

5. How We Use Your Information

Your information is used strictly for lawful business purposes, including:

  • Processing bill payments
  • Facilitating POS transactions
  • Identity verification (KYC/AML compliance)
  • Fraud prevention and risk assessment
  • Transaction reconciliation and settlement
  • Customer support and dispute resolution
  • Regulatory reporting
  • Improving user experience
  • Internal audits and analytics
  • Sending important service notifications

We do not sell your personal data.

6. Cookies & Tracking Technologies

SmartPay may use cookies and similar technologies to:

  • Improve performance
  • Remember user preferences
  • Analyze usage patterns
  • Enhance security

Cookies do not store sensitive personal information.

7. Disclosure of Information

SmartPay may share your information only when necessary and lawful, including with:

A. Regulated Financial Institutions

  • Banks
  • Payment processors
  • Mobile wallet operators
  • Licensed financial service providers

B. Regulatory Authorities

  • State Bank of Pakistan (SBP)
  • SECP (where applicable)
  • Law enforcement agencies
  • Courts or government bodies

C. Service Providers

  • Technology partners
  • Cloud hosting providers
  • Fraud detection vendors
  • Customer support platforms

D. Business Transfers

In case of merger, acquisition, or asset transfer, user data may be transferred under confidentiality obligations.

All third parties are contractually required to maintain strict confidentiality and data protection standards.

8. 1Link Dispute & Settlement Escalation Clause

  • Transaction logs may be shared with 1Link for investigation.
  • Reversals and chargeback timelines are governed by 1Link operational rules.
  • Settlement delays may occur due to technical or reconciliation issues.
  • Unresolved matters are escalated via 1Link dispute resolution channels.
  • Customers are notified of material delays impacting transaction settlement.

9. SBP-Compliant Complaint Handling & Escalation Matrix

StepActionTimelineContact
1Submit complaint to SmartPay Customer SupportWithin 24 hours acknowledgmentsupport@smartpay.pk
2Internal investigation & resolution3–5 business daysSupport escalation team
3Escalation to Partner Bank / 1Link5–7 business daysbank/1link escalation desk
4Escalation to SBP for unresolved complaints10 business days after Step 3Consumer Protection Dept., SBP

10. Data Storage & Security

Your data is stored on secure servers located within Pakistan or approved jurisdictions.

We implement:

  • TLS/SSL encryptioz
  • Secure API integrations
  • Role-based access controls
  • Firewalls and intrusion detection
  • Encrypted data storage
  • Automatic session timeout (auto logout)

While we take reasonable security measures, no system is 100% secure.

11. Data Retention

We retain your information:

  • As long as required to provide Services
  • As required under SBP and applicable regulatory requirements (e.g., up to 10 years where mandated)
  • For dispute resolution and legal compliance

Once no longer required, data is securely deleted or anonymized.

12. Your Rights

  • Access personal data
  • Request corrections
  • Withdraw consent where legally permitted
  • Request deletion subject to SBP retention rules

Requests may be submitted via our official support channels.

13. Withdrawal of Consent

You may withdraw consent by:

  • Deleting your SmartPay account
  • Uninstalling the application
  • Contacting customer support

However, certain data may be retained for regulatory compliance.

14. Marketing Communications

We may send service-related notifications and, where permitted, promotional communications.

You may opt out of promotional communications at any time.

15. Protection Against Fraud & Misuse

SmartPay reserves the right to:

  • Investigate suspicious transactions
  • Report fraud to regulatory authorities
  • Suspend accounts involved in misuse
  • Initiate recovery proceedings where necessary

16. Contact Us

If you have questions about this Privacy Policy or how your data is handled, please contact:

SmartPay Customer Support

Email: info@smartpay.com.pk
Website: www.smartpay.com.pk