Privacy Policy

Barter Funds ("Barter Funds", "we", "us", or "our") operates a digital financial platform that enables users to buy, sell, send, and receive digital assets and currencies, redeem gift cards, make Concierge Pay international payments, and hold balances in a Barter Wallet. We are headquartered in Accra, Ghana and serve users across Ghana, Nigeria, Kenya, and other supported jurisdictions. This Privacy Policy explains how we collect, use, disclose, retain, and safeguard your personal data when you use our website (barterfunds.com), our mobile applications, and our services (collectively, the "Services"). It applies to all users, prospective users, and visitors. This Policy is published in accordance with the Ghana Data Protection Act, 2012 (Act 843), the Nigeria Data Protection Act, 2023, the Kenya Data Protection Act, 2019, the General Data Protection Regulation (EU 2016/679) and the UK GDPR where applicable to users in those jurisdictions, and other applicable data protection laws.

Barter Funds is the data controller responsible for your personal data. For any privacy enquiry, request, or complaint, contact our Data Protection Officer: Barter Funds - Data Protection Officer Email: privacy@barterfunds.com Support: support@barterfunds.com WhatsApp: +233 53 036 7164 Address: Accra, Ghana You may also lodge a complaint with the relevant supervisory authority, including the Data Protection Commission (Ghana), the Nigeria Data Protection Commission, or the Office of the Data Protection Commissioner (Kenya), without prejudice to any other administrative or judicial remedy.

We collect the following categories of personal data: a) Account & Identity Data: full name, email address, phone number, date of birth, residential address, nationality, and a profile photograph. b) KYC & Verification Data: government-issued identification (Ghana Card, passport, or driver's licence) including front and back images, the ID number, and a live selfie; for business accounts, beneficial ownership and corporate registration documents. c) Transaction Data: transaction type (Buy, Sell, Send, Receive, Concierge Pay, gift card redemption), currency, amount, exchange rate, fees, payout account details (mobile money number, bank account number and holder name), payment references, and timestamps. d) Financial & Payment Data: deposit and withdrawal records, Barter Wallet balances, payment method identifiers, and proof-of-payment uploads. e) Device & Usage Data: IP address, browser type, operating system, device identifiers, geolocation derived from IP, pages viewed, clickstream data, and activity within the app. f) Communications Data: records of support tickets, chat transcripts (including AI support conversations and any escalation history), emails, SMS, and call recordings where applicable. g) Referral Data: referrer and referred email addresses, referral codes, and reward entitlements. We do not collect more data than is necessary for the purposes described below.

We process your personal data for the following purposes: • To create, verify, and administer your account and to complete KYC/AML verification as required by law. • To execute, confirm, and settle your transactions, including payouts to your mobile money or bank account and crediting your Barter Wallet. • To determine and display applicable exchange rates, fees, and limits, and to generate receipts. • To detect, prevent, and investigate fraud, money laundering, terrorism financing, and other financial crime. • To communicate with you about your account, transactions, security alerts, and service changes. • To provide customer support and to resolve disputes and complaints. • To maintain records as required by AML/CFT and tax laws (typically five years). • To improve our Services, conduct analytics, and perform product development. • To comply with legal, regulatory, and law-enforcement obligations.

Where the GDPR applies, we rely on the following legal bases: • Performance of a contract: processing necessary to deliver the Services you requested (account, transactions, payouts). • Compliance with a legal obligation: KYC/AML record-keeping, transaction monitoring, and regulatory reporting. • Consent: marketing communications, cookies, and certain optional data uses, which you may withdraw at any time. • Legitimate interests: fraud prevention, network and information security, and internal analytics, balanced against your rights. Where we rely on consent, you have the right to withdraw it at any time by contacting privacy@barterfunds.com. Withdrawing consent does not affect the lawfulness of processing before withdrawal.

We use cookies and similar technologies (local storage, pixels) to operate the platform, remember your preferences, secure your session, and understand usage. Essential cookies are required for the Services to function; optional analytics and marketing cookies are set only with your consent where required by law. You can manage or disable cookies through your browser settings. Disabling non-essential cookies may limit some features. See our Cookie Policy for full details.

We do not sell your personal data. We share it only with the following categories of recipients, where necessary: • Payment and payout partners: mobile network operators (MTN, Telecel, AirtelTigo), banks, and licensed payment processors such as Moolre, Paystack, and FinCra, to route deposits and payouts. • Identity verification and screening providers: to validate your documents and screen against sanctions and PEP lists. • Cloud and infrastructure providers: to host and operate the platform, all under written data-protection obligations. • Regulators and law enforcement: where required by law, court order, or to fulfil AML/CFT reporting obligations. • Professional advisers: auditors, lawyers, and tax advisers acting on our behalf. All processors and recipients are bound by confidentiality and, where applicable, by data processing agreements.

Because we and our service providers operate across multiple countries, your personal data may be transferred to, stored, or processed in countries outside your residence, including Ghana, Nigeria, Kenya, the European Economic Area, the United Kingdom, and the United States. Where such transfers occur, we ensure an adequate level of protection through applicable adequacy decisions, standard contractual clauses, binding corporate rules, or other lawful transfer mechanisms, and we apply safeguards consistent with Act 843 and the GDPR.

We retain your personal data only for as long as necessary to fulfil the purposes set out in this Policy and to comply with legal obligations: • KYC and transaction records: a minimum of five (5) years after the end of the business relationship or the date of the transaction, as required by Ghana's Anti-Money Laundering Act, 2008 (Act 749) and equivalent AML/CFT laws. • Account data: for the life of your account and a reasonable period after closure for audit, dispute, and legal compliance. • Marketing data: until you opt out. • Logs and analytics: retained in aggregate for the shortest period consistent with the purpose. You may request earlier deletion where the law permits and no retention obligation applies.

We implement industry-standard technical and organisational measures to protect your personal data, including: • Encryption in transit (TLS) and at rest for sensitive data. • Access controls limited to authorised personnel on a least-privilege basis. • Multi-factor authentication and passkeys for account access. • Regular security testing, monitoring, and incident response procedures. • Segregation of KYC documents and financial records. No system is perfectly secure. In the event of a personal data breach likely to result in a risk to your rights, we will notify the relevant supervisory authority and, where required, affected individuals, without undue delay and in accordance with the law.

Subject to applicable law and our AML/CFT retention obligations, you have the following rights: • Right of access: to obtain confirmation of processing and a copy of your personal data. • Right to rectification: to correct inaccurate or incomplete data. • Right to erasure: to request deletion where no legal retention obligation applies. • Right to restriction: to limit processing in defined circumstances. • Right to data portability: to receive certain data in a structured, machine-readable format. • Right to object: to object to processing based on legitimate interests or for direct marketing. • Right to withdraw consent: at any time, where processing relies on consent. • Rights relating to automated decision-making: to not be subject to decisions based solely on automated processing that produce legal effects, except as permitted. To exercise any right, contact privacy@barterfunds.com. We will respond within one month, extendable by two months where necessary, and may verify your identity before acting.

Our Services are not directed to, and may not be used by, anyone under eighteen (18) years of age. We do not knowingly collect personal data from minors. If you believe a minor has provided data to us, contact privacy@barterfunds.com and we will take steps to delete it.

Identity verification data is collected and retained under legal obligation and cannot be deleted at your request while the retention period applies. We may be required to continue processing such data even after your account is closed, to satisfy AML/CFT, tax, and law-enforcement requirements. This constitutes processing necessary for compliance with a legal obligation and overrides certain erasure rights to that extent only.

With your consent, we may send you promotional emails and SMS about our Services. You may opt out at any time via the unsubscribe link in any email, by replying STOP to an SMS, or by adjusting your notification preferences in the app. Transactional messages (account security, transaction confirmations) are not marketing and will continue regardless.

We may update this Privacy Policy from time to time to reflect changes in our practices, the Services, or the law. We will notify you of material changes by email or a prominent notice in the app and update the "Last updated" date. Continued use of the Services after a change constitutes acceptance of the revised Policy.

To exercise any privacy right, raise a concern, or make a complaint, contact our Data Protection Officer at privacy@barterfunds.com. If you are unsatisfied with our response, you may complain to the Data Protection Commission (Ghana), the Nigeria Data Protection Commission, or your local supervisory authority. We will not retaliate against you for exercising your rights.