PartnaPay

Privacy Policy

Your information, handled with care.

Last updated

Draft, pending legal review

This page is a working draft. It has not yet been reviewed by legal counsel and may change before PartnaPay launches. Text in square brackets is a placeholder that will be completed during that review.

This policy explains what PartnaPay collects when you use our website and apps, why we collect it, and the choices you have. Read it with our Terms of Service.

01Who we are

PartnaPay is operated by [Legal entity name], [Registered address] (“PartnaPay”, “we”, “us”). This policy covers the PartnaPay website, the organizer console, and the PartnaPay mobile apps.

For privacy questions or requests, contact [Privacy contact email].

02Information we collect

We collect only what we need to run partner draw groups:

  • Account details: your name, email address, and password. Passwords are stored as one-way hashes, never in plain text. A phone number or profile photo is stored only if you add one.
  • Group activity: the groups you organize or join, the hands you hold, the group rules and fee disclosure you accepted and when, contribution and payout records, late flags, waivers, receipts, and disputes you raise or respond to.
  • Card details: card numbers and security codes are passed straight to our card processor and are never stored by PartnaPay. We keep only a token from the processor plus the card brand, last four digits, and expiry date so you can recognise the card.
  • Payout details: to receive a payout you may add a bank account. We store the account holder name, bank name, account type, routing number, and the last four digits of the account number. We do not keep the full account number.
  • Waitlist details: if you join the waitlist, your email address and, optionally, your first name.
  • Technical information: sign-in session records, IP address, and browser or device type, used to keep your account secure and to limit abuse. The mobile app stores a push notification token if you allow notifications.
  • Diagnostics: when something breaks we may record an error report. Error reports are configured to leave out email addresses and the contents of forms you submit.

03How we use your information

  • To create and secure your account and keep you signed in.
  • To run your groups: schedules, hands, contribution tracking, payout order, receipts, and dispute handling.
  • To send service messages such as payment reminders and notices about your groups and your account.
  • To prevent fraud and abuse, including limiting repeated sign-in or sign-up attempts.
  • To answer support requests and fix problems.
  • To meet legal, accounting, and regulatory obligations.
  • If you joined the waitlist, to manage your place and tell you when PartnaPay is ready for you.

We do not sell your personal information, and we do not use it for third-party advertising.

The legal bases we rely on under [Applicable data protection law] will be confirmed during legal review.

04Who can see your information

People in your groups. Groups are private and invite-only. Organizers and members of a group can see your name, the hands you hold, your place in the payout order, and the status of the contributions and payouts in that group. Organizers can see who has paid, who is late, and any disputes raised in their group.

Service providers. We use trusted providers to run PartnaPay, each limited to what their service needs: application hosting and database, email delivery, mobile push notifications, card processing, and error monitoring. [List of service providers]

Legal reasons. We may disclose information when the law requires it, or to protect the safety and rights of our users and of PartnaPay.

05Cookies and local storage

We use a small number of essential cookies to keep you signed in and to protect your session. Your browser also remembers your light or dark display preference. We do not use advertising or cross-site tracking cookies.

06How long we keep information

We keep account and group information while your account is open. Payment, payout, and audit records may need to be kept for longer to meet accounting and legal requirements, even after you close your account. Waitlist details are kept until PartnaPay launches for you or you ask us to remove them.

Specific retention periods: [Retention periods]

07Your choices and rights

You can update your profile in the app. You can also ask us to give you a copy of your information, correct it, or delete your account by writing to [Privacy contact email]. Some records, such as completed payments, may need to be kept as described above.

You can turn off push notifications in your device settings, and you can leave the waitlist at any time by contacting us.

08How we protect information

Information is encrypted in transit, access is limited by role, and passwords are hashed. Card data is handled by our card processor rather than stored by us. No system is perfectly secure; if you believe your account has been compromised, contact us straight away.

09Where information is processed

PartnaPay is built for groups in Jamaica and the wider Caribbean. Some of our service providers process information in other countries, including the United States. Where that happens we rely on providers that protect information to a comparable standard.

10Children

PartnaPay is not intended for anyone under [Minimum age], and we do not knowingly collect information from them.

11Changes to this policy

We will update this page when our practices change, and tell you in the app or by email about significant changes. The date at the top shows when it last changed.

12Contact

Questions about this policy can be sent to [Privacy contact email]. For help with your account or a group, see Support.