Privacy Policy

Last updated: 24 July 2026

1. Introduction

Capitel C Ltd ("we", "our", "us") is committed to protecting your personal data. This privacy policy explains how we collect, use, and safeguard your information when you use our money transfer service.

We are registered in the United Kingdom and comply with the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018.

2. Data We Collect

We may collect and process the following personal data:

  • Identity Data: full name, date of birth, passport or national ID details
  • Contact Data: email address, phone number, residential address
  • Financial Data: bank account details, transaction history, wallet balance
  • Transaction Data: transfer amounts, recipient details, payment references
  • Technical Data: IP address, device information, browser type, app usage data
  • Verification Data: passport copy, proof of address documents
  • Device Data: camera-captured document photos, GPS location (collected at the point of transfer for fraud screening)

3. How We Use Your Data

We use your personal data for the following purposes:

  • To process and complete your money transfers
  • To verify your identity and comply with anti-money laundering (AML) regulations
  • To communicate with you about your transactions and account
  • To improve and maintain our service
  • To capture your device location at the point of transfer for fraud prevention and regulatory compliance
  • To capture document photos using your device camera for identity verification (KYC)
  • To prevent fraud and ensure the security of our platform
  • To comply with legal obligations under UK law

Our legal basis for processing includes: contract performance, legal obligation, legitimate interest, and your consent where applicable.

4. Data Sharing

We may share your data with:

  • Payment partners and banking institutions to process transfers
  • Regulatory bodies as required by UK law
  • Service providers who help us operate our platform

We do not sell your personal data to third parties.

5. Data Retention

We retain your personal data for as long as your account is active, and for a period of 6 years after account closure to comply with UK financial regulations and tax obligations.

6. Your Rights

Under UK GDPR, you have the right to:

  • Access the personal data we hold about you
  • Request correction of inaccurate data
  • Request deletion of your data (subject to legal retention requirements)
  • Restrict or object to processing of your data
  • Data portability
  • Withdraw consent where processing is based on consent

To exercise any of these rights, contact us at finance@capitelc.co.uk.

7. Data Security

We implement appropriate technical and organisational measures to protect your personal data against unauthorised access, alteration, disclosure, or destruction.

8. International Transfers

When you send money to Zimbabwe or South Africa, we share necessary recipient data with our payout partners in those countries. We ensure appropriate safeguards are in place for any international data transfers.

9. Cookies

Our app uses essential cookies to maintain your session and ensure secure authentication. We do not use tracking cookies for advertising purposes.

10. Data Safety

The following section provides a detailed summary of the data our app collects, shares, and handles, in accordance with app store data safety requirements.

Data We Collect

  • Personal Information: full name, email address, phone number, date of birth, residential address
  • Government IDs: passport number, issuing country, expiry date, and uploaded passport document (image or PDF)
  • Verification Documents: proof of address document (image or PDF), deposit receipts
  • Financial Information: bank account number, bank name, account holder name, routing/sort code, account type, wallet balance, transaction amounts (GBP, USD, ZAR), transfer fees, exchange rates
  • Recipient Information: recipient full name, phone number, country, city or payout location, relationship to sender, bank name and account number (South Africa), delivery method
  • Transaction Data: transaction history, transfer references, confirmation codes, transfer reasons/notes, document approval status
  • Technical Data: IP address, authentication tokens, session data
  • Device & Sensor Data: photos captured via the device camera for KYC verification; GPS coordinates captured at the point of transfer for fraud screening

Device Permissions

Our iOS app requests the following device permissions, used only for the purposes below:

  • Camera: to photograph your passport and proof of address for identity verification. Photos are uploaded securely and are not stored on your device.
  • Location (When In Use): to capture your approximate location when you submit a money transfer, as part of our fraud screening and regulatory compliance measures. Location is optional — if denied, you may still send transfers, but the transfer will be flagged for additional review.

Data We Share

  • Recipient name and phone number with payout partners (Gain stores, mobile money providers) for cash collection and transfer delivery
  • Recipient bank details with the recipient's bank for bank transfer delivery (South Africa)
  • Transaction confirmation codes with the recipient for cash collection at Gain stores in Zimbabwe
  • Deposit notifications with our finance team (finance@capitelc.co.uk) for manual deposit approval
  • Transfer confirmation emails to the sender and recipient

Data We Handle (Process)

  • Currency conversion (GBP to USD for Zimbabwe, GBP to ZAR for South Africa) using live exchange rates
  • Document review and approval by our admin team for KYC/AML compliance
  • Wallet balance updates for transfers and deposits
  • Account deletion requests processed via our support team

Data Security

  • All data is encrypted in transit using HTTPS/SSL
  • All stored data is encrypted at rest (platform-managed)
  • Access to personal data is restricted to authorised personnel only
  • Users can request data deletion at any time by contacting support

11. Contact & Complaints

For privacy inquiries, contact our Data Protection Officer at finance@capitelc.co.uk.

You also have the right to lodge a complaint with the UK Information Commissioner's Office (ICO) at ico.org.uk.