Effective Date: March 1, 2025 | Last Updated: March 2025
| Category | Data Collected | Why Required |
|---|---|---|
| Identity | Full legal name, date of birth, residential address | KYC / BSA legal requirement |
| Government ID | Photo ID scan (front & back), selfie / liveness check | KYC identity verification |
| Tax ID | Last 4 digits of SSN | FinCEN / IRS compliance |
| Contact | Email address, US phone number | Account access, 2FA, notifications |
| Payment | Bank account (via Plaid), card (tokenized via Stripe — never stored by Waari) | Payment processing |
| Plaid Data | Bank account ownership, balance, risk signal, consent record | Fraud prevention, ACH authorization |
| Recipients | Name, country, mobile number, mobile money operator | Transfer delivery |
| Pari Groups | Group name, member list, contribution history, rotation schedule | Pari product operation |
| Transactions | Amount, currency, destination, timestamp, payment method, reference number | Service delivery, BSA recordkeeping |
Device type, operating system, browser type, IP address, approximate location, usage data, and transaction metadata — collected for fraud detection, security monitoring, and service improvement.
| Partner | Role | Data Shared |
|---|---|---|
| Stripe | US payment processing | Name, email, tokenized card/bank details, transaction amount |
| Plaid | Bank verification & fraud prevention | Bank login (processed by Plaid only), account ownership data |
| Pawapay | Africa mobile money payout & collection | Recipient name, mobile number, amount, country |
| Persona | KYC identity verification | ID documents, selfie, personal details |
| Comply Advantage | AML / sanctions screening | Name, DOB, address, nationality |
| Twilio | SMS & WhatsApp notifications | Phone number, transfer amounts, Pari reminders |
| Bubble.io | App platform & database hosting | All user data stored in Bubble database |
| Stripe Treasury | Pari interest-bearing accounts | Account balance, group membership, interest earned |
We may disclose your information to government authorities when required by law, including Suspicious Activity Reports (SARs) filed with FinCEN, Currency Transaction Reports (CTRs) for transactions over $10,000, and responses to valid legal process such as subpoenas or court orders.
Waari will never sell, rent, or trade your personal information to advertisers, data brokers, or any third party for marketing purposes. Your financial data is not a product.
| Data Category | Retention Period | Legal Basis |
|---|---|---|
| Transaction records | 5 years minimum | Bank Secrecy Act — mandatory |
| KYC identity records | 5 years from account closure | BSA / FinCEN — mandatory |
| Plaid consent records | 5 years | Fraud prevention & dispute resolution |
| AML screening records | 5 years | BSA / FinCEN — mandatory |
| Marketing preferences | Until you opt out | Your consent |
We cannot delete financial transaction or KYC records before the legally mandated retention period, even upon account closure or deletion request.
If a security breach occurs affecting your personal information, we will notify you within 72 hours of becoming aware of the breach as required by applicable law.
California residents have additional rights under CCPA including the right to know, right to delete, and right to non-discrimination. Submit requests to hello@waari.app with "Privacy Request" in the subject line. We respond within 30 days.
As a financial services company, Waari collects nonpublic personal information (NPI) including account application data, transaction information, and identity verification results. We disclose NPI only to service providers who help us provide financial services and to government agencies as required by law. We do not share NPI with non-affiliated third parties for marketing. To limit sharing, email hello@waari.app with "Opt Out of Sharing" in the subject line.
Waari is not directed to individuals under 18 years of age. We do not knowingly collect personal information from minors. If you believe a minor has created a Waari account, contact hello@waari.app immediately.
To deliver transfers to recipients in West Africa, recipient payment data is processed by Pawapay, which operates in multiple countries. This transfer is necessary to provide the service and is protected by data processing agreements. By joining a cross-border Pari group, you consent to international data processing for your contribution data.
We will notify you of material changes by email at least 30 days before the effective date and post the updated policy at waari.app/privacy. Continued use constitutes acceptance.