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Effective Date: 4 July 2026
Last Updated: 4 July 2026
Operating Entity: EHSAN FALCON HOLDING LIMITED ("EFH LTD")
Registered in the United Kingdom
Company Registration Number (Companies House): 17091849
Registered Address: 71-75 Shelton Street, Covent Garden, London, WC2H 9JQ, United Kingdom
EHSAN FALCON HOLDING LIMITED ("EFH LTD"), registered in the United Kingdom, operates the ZovoPay digital wallet and financial solutions platform, including the User App, the unified Business App (Merchant/Agent/Company), and the website zovopay.com (collectively, the "Services"). EFH LTD provides financial services to customers across the Middle East, Turkey, and the United Kingdom. EFH LTD is referred to hereinafter as "we," "us," or "the Company."
We understand that money demands a higher standard of trust. This policy honestly and transparently explains: what data we collect, why we collect it, how we protect it, with whom we share it, and what your rights are.
By using the Services, you agree to the privacy practices described in this policy.
At registration we collect:
To comply with anti-money laundering (AML) and counter-terrorism financing (CTF) regulations, we collect:
For every financial operation conducted on our platform we retain:
Any information you voluntarily provide, such as a profile photo or saved recipient contact details.
We use the data we collect solely for the following purposes:
| Purpose | Legal Basis |
|---|---|
| Providing financial services and executing transactions | Contractual necessity |
| Identity verification (KYC/AML) and legal compliance | Legal obligation |
| Fraud prevention, AML, and counter-terrorism financing | Legitimate interest + Legal obligation |
| Sending financial notifications (money received, transaction completed) | Contractual necessity |
| Customer support and dispute resolution | Contractual necessity + Legitimate interest |
| Service improvement and technical performance | Legitimate interest |
| Compliance with legal and regulatory requests | Legal obligation |
| Marketing communications (with your consent) | Explicit consent |
We do not use your data for third-party advertising. We do not sell your data.
We share your data only in the following circumstances:
We share the minimum data necessary to complete your transactions with:
Manual deposit and withdrawal methods (bank transfer and local cash channels) do not transmit your data automatically through the app; they are executed outside the app and reconciled based on a reference or receipt you provide.
To execute international remittances, the minimum necessary data may be shared with our licensed and approved remittance partners.
We may disclose data when:
We engage trusted service providers to operate our infrastructure (hosting, push notifications, performance analytics). These providers are contractually bound to process data solely for the purpose of the service.
In the context of cash-in operations, the agent accesses the minimum data necessary to execute the transaction (customer name and phone number) pursuant to compliance requirements, and is not permitted to retain or use that data for any other purpose.
We implement serious technical and organisational measures to protect your data, including:
Despite our commitment to high security standards, no method of internet transmission is 100% guaranteed. In the event of a security breach affecting your data, we will notify you in accordance with applicable legal requirements.
| Data Type | Retention Period |
|---|---|
| Account data and KYC records | Five (5) years after account closure, in accordance with applicable anti-money laundering standards |
| Financial transaction records | Five (5) years, in accordance with applicable regulatory requirements in operating jurisdictions |
| Technical support logs | Two (2) years |
| Technical performance data / crash logs | 90 days |
| Marketing data (with your consent) | Until consent is withdrawn |
Upon expiry of the applicable retention period, data is securely deleted or anonymised.
You have the right to:
To exercise these rights, contact us at: support@zovopay.com
We will respond to privacy requests within thirty (30) days of receipt.
You may request deletion of your account at any time through any of the following:
What happens when you request deletion:
On the website (zovopay.com):
We use technically necessary cookies to operate the website and maintain secure sessions. We will update this policy if additional analytics tools are adopted.
On the app:
We do not use cookies in the app. We use anonymised device identifiers for security and push-notification purposes.
ZovoPay services are directed to persons aged 18 years or older (or the legal age for financial eligibility in your country of residence if higher). We do not knowingly collect data from persons under the age of 18. If we discover that a minor has opened an account, we will suspend the account, contact the guardian, and delete the data in accordance with applicable legal procedures. If you are a guardian and believe your child has submitted data to us, please contact us immediately.
Our data is hosted on secure servers with reputable hosting providers. Your data may be transferred to and processed in countries other than your country of residence; in all cases, the protections described in this Policy apply.
We may update this policy periodically. Where material changes are made, we will notify you by registered email or in-app notification at least 30 days before the change takes effect. Your continued use of the Services after the change takes effect constitutes your acceptance of the updated policy.
For any privacy-related enquiry or request:
If you are not satisfied with our response, you have the right to lodge a complaint with the data-protection authority in your country of residence; in the United Kingdom, the Information Commissioner's Office (ICO).