Privacy(draft).

This privacy page is a draft template being prepared for review by legal counsel. It is provided for transparency about the intended scope of the future Paysos privacy policy. It is not final legal advice and should not be relied on as an approved policy.

Paysos is a Colombia-wide financial platform. Paysos is not a bank. Services are subject to applicable approvals, availability, eligibility, and partner arrangements, and may be provided directly or through licensed partners where applicable.

The future Paysos privacy policy is intended to describe how Paysos may collect, use, and share information when people, merchants, businesses, and developers use Paysos products, including digital wallets, digital accounts, cards where available, merchant payments, business accounts, and developer APIs.

Until a final policy is approved, this draft outlines the categories of information and the purposes for which information may be processed.

Subject to applicable approvals and product availability, information may include:

• Account information such as name, email, phone, and country or city.
• Identity information required to comply with regulatory requirements.
• Product and transaction information related to wallets, accounts, cards where available, and merchant payments.
• Device, browser, and usage information collected automatically.
• Communications you send to Paysos support, sales, partnerships, or compliance.

Information may be used, where applicable, to:

• Provide, configure, and maintain Paysos services.
• Verify identity and meet compliance obligations designed for regulated financial services.
• Process transactions and reconcile activity.
• Detect, prevent, and respond to fraud and security risks.
• Improve product reliability, performance, and user experience.
• Communicate with you about your use of Paysos and respond to requests.

Paysos services involving wallets, digital accounts, cards where available, merchant payments, business accounts, or APIs may require identity verification. Verification is performed in line with applicable Colombian regulatory requirements and may be conducted by Paysos or by licensed partners where applicable. Final scope and retention rules will be described in the approved policy.

When you use a Paysos wallet, digital account, card where available, or merchant payment product, Paysos may process information about the transaction, the parties involved, the device used, and the configuration of the product. This information supports operational, regulatory, security, and reporting requirements.

Paysos web properties may use cookies and similar technologies for essential functionality, and, where applicable and only after consent is enabled, for analytics and marketing. See the Cookies (draft) page for the proposed approach. Cookie consent is not wired yet.

Paysos may share information with service providers, processors, and licensed partners where applicable, including for the purposes of providing the platform, operating payments, meeting regulatory obligations, and supporting fraud prevention.

The approved policy will list categories of recipients. Paysos will not sell personal information.

Paysos intends to apply technical and organizational measures appropriate to the financial services context, including encryption in transit, access controls, and monitoring. Retention periods will be defined in the approved policy and aligned with regulatory requirements. No system is perfectly secure, and Paysos does not promise absolute security.

Users may have rights with respect to their personal information under applicable Colombian law, including rights to access, correction, and deletion, subject to legal and operational exceptions.

The approved policy will describe how to exercise these rights and any limits that apply for regulated financial services.

Some processing may take place outside Colombia, for example through service providers or licensed partners where applicable. If that occurs, Paysos intends to apply safeguards consistent with applicable Colombian data protection requirements. The approved policy will describe these safeguards.

For questions about this draft, write to legal@paysos.co or use the Paysos contact page. This contact channel is provided as a placeholder for future support.

This draft has not been reviewed or approved by legal counsel. Paysos will replace this page with an approved privacy policy before live services are enabled. Until then, this page does not create any legal commitments.