Privacy Policy

1. Who we are

UltPay is a money transfer service operated by Enterprise ENP Technology, LLC, a Limited Liability Company registered in the Commonwealth of Virginia, USA (Virginia SCC Entity ID: S5292240), with its principal office at 300 S Van Dorn St R401, Alexandria, VA 22304, USA.

In this policy "UltPay", "we", "us" and "our" refer to Enterprise ENP Technology, LLC. "You" and "your" refer to any person who uses our website at www.ultpay.net or our mobile application.

2. Information we collect

We collect the following categories of personal data:

• Identity data: full name, date of birth, government-issued ID documents (passport, national ID, driving licence).
• Contact data: email address, phone number, country of residence.
• Financial data: source and destination amounts, currency, beneficiary account details (bank account number, mobile money number).
• KYC / verification data: selfie photos and identity document scans processed by our third-party identity verification provider (Sumsub).
• Technical data: IP address, browser type, operating system, device identifiers, and usage logs.
• Transaction data: records of money transfers you have sent or received through UltPay.

3. How we use your information

• To create and manage your account.
• To process and execute money transfers on your behalf.
• To comply with anti-money laundering (AML) and Know Your Customer (KYC) obligations under applicable US law.
• To verify your identity through our KYC provider (Sumsub).
• To detect and prevent fraud, money laundering, and other illegal activity.
• To communicate service updates, transaction receipts, and support responses.
• To improve our platform and user experience.

4. Legal basis for processing

We process your personal data on the following legal bases:

• Performance of a contract: to provide you with the money transfer service you signed up for.
• Legal obligation: to comply with AML, KYC, and financial regulations.
• Legitimate interests: fraud prevention, security, and service improvement.
• Consent: for optional communications such as marketing emails (you may withdraw consent at any time).

5. Sharing your information

We share personal data only where necessary:

• Sumsub (sumsub.com) — identity verification and KYC processing.
• Flutterwave (flutterwave.com) — payment processing and fund disbursement to recipients.
• Microsoft Azure — cloud infrastructure hosting our platform and databases.
• Regulatory authorities — when required by law, court order, or government request.

We do not sell your personal data to third parties.

6. Data retention

We retain your personal data for as long as your account is active and for at least 5 years after your last transaction, as required by US financial regulations. KYC documents may be retained for up to 7 years.

7. Your rights

Depending on your location, you may 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).
• Object to or restrict processing of your data.
• Receive a copy of your data in a portable format.

To exercise any of these rights, email us at privacy@enptechno.com.

8. Cookies

We use only essential cookies required for the platform to function (session authentication). We do not use advertising or tracking cookies.

9. Security

We implement industry-standard security measures including HTTPS encryption, hashed password storage (PBKDF2-SHA256), and access controls on all systems. Despite these measures, no internet transmission is 100% secure and we cannot guarantee absolute security.

10. Changes to this policy

We may update this Privacy Policy from time to time. We will notify you of material changes by email or by posting a notice on our website. Your continued use of UltPay after changes take effect constitutes acceptance of the updated policy.

11. Contact us

If you have questions or concerns about this Privacy Policy, please contact: