Legal

Privacy Policy

Effective date: 13 August 2026 Last updated: 13 August 2026

This policy explains what information HilalPay collects, how we use and share it, and the choices you have. We have written it to describe what the app and our systems actually do, in plain language.

1. Introduction

Hilal Fintech (Private) Limited ("HilalPay", "we", "us", or "our") operates the HilalPay mobile application (the "App") — a digital khata and invoice-financing app for retail businesses in Pakistan, and the website at hilalpe.com.

By creating an account or using the App, you agree to the collection and use of information as described in this policy. If you do not agree, please do not use the App.

This policy applies to merchants, shopkeepers and business owners who register for or use HilalPay, and to visitors to our website.

2. Scope

This policy covers information we process through the App, our website, and the systems that support them. It also covers information we receive about you from our business partners, described in section 3.8.

Some of the companies we work with process information on our behalf — for example our identity-verification provider and our cloud hosting providers. They act on our instructions, and we remain responsible for that information. They are listed in section 7.

3. Information we collect

3.1 Information you give us

3.2 Identity verification (KYC)

To use certain features, including invoice financing, you must complete identity verification.

Verification through our partner Didit. By default, identity verification is carried out by our partner Didit through a secure, hosted flow. That flow captures images of your identity document (CNIC front and back), a selfie photograph, and a "liveness" check that confirms a real person is present.

What we receive and keep. Didit returns the verification outcome to us together with the information it read from your document and the checks it performed. We receive and store your full name, date of birth, document number, the portrait image taken during verification, and the scores indicating how closely your selfie matched your document and whether the liveness check passed. We also keep a copy of your identity document images and selfie in our own secure storage.

If verification cannot be completed. If Didit rejects or cannot verify part of your information, we may ask you to provide or correct only the specific items flagged — which may include your full name, CNIC number, date of birth, address, or a selfie. Only the flagged information you submit at that step is uploaded to our systems.

We use identity-verification data only to verify who you are and to meet our regulatory obligations. We do not use your selfie for any facial-recognition purpose unrelated to verifying your identity, and we do not sell it.

3.3 Voice commands

If you use the voice command feature, the App records a short audio clip — up to ten seconds — and sends it to our servers. We then pass that recording to Google's Gemini service, which converts your speech to text and identifies what you asked for, such as recording a payment. Google processes the recording on our behalf in order to return that result to us.

To act on your instruction, we match the names in it against the customer records in your own ledger. We keep voice recordings for up to 30 days and then delete them. You can choose not to use the voice feature; nothing else in the App depends on it.

3.4 Business location

With your permission, we use your device's location to help you set your business location during sign-up, and to show it on a map (using Google Maps). We use location only at the point you set or update your business location. We do not track your location in the background, and we do not follow your movements.

3.5 Customer contacts

When you add a customer to your ledger, you can either type their details or pick someone from your phone's contacts. If you pick a contact, your device shows you the picker and passes us only the single contact you chose — we receive that person's name and phone number, and nothing else from your address book. You can always enter customers manually instead.

If you add a customer's details to HilalPay, you are responsible for having the right to share them with us. We use those details only to maintain your ledger and, where you ask us to, to send that customer a payment reminder.

3.6 Images

With your permission, we use your camera so you can scan QR codes, capture identity documents, and photograph your shop. You can also select an existing image from your device to upload. We only ever receive images you deliberately capture or select.

3.7 Information we collect automatically

We do not use any advertising networks, and we do not include analytics, tracking or profiling software from third parties in the App.

3.8 Information we obtain from our business partners

We work with distribution partners who supply goods to retail businesses. Where you buy from one of these partners, we receive records about your business from them — including your business name and contact details, your CNIC and tax registration numbers, and your purchase, invoice and payment history with that partner.

We may receive this information before you have an account with us. We use it to assess creditworthiness as described in section 6, and to identify businesses we can invite to use HilalPay. If you would like to know what we hold about your business, or ask us to stop using it, contact us using the details in section 15.

4. App permissions

You can grant or refuse each permission, and change your mind later in your device settings. Some features will not work without the relevant permission.

PermissionWhy we ask for it
CameraScan QR codes, capture identity documents, and take shop or receipt photos
MicrophoneRecord voice commands, only while you are using the voice feature
LocationSet and display your business location during sign-up
NotificationsSend you transaction alerts and repayment reminders

Choosing a photo or a contact does not require you to grant us access to your gallery or your address book — your device shows you a picker and passes us only the item you select.

5. How we use your information

We use your information to:

6. How we assess creditworthiness

When we decide whether to offer you financing and how much, we assess the risk using information about your business. This includes your purchase and repayment history with our distribution partners, how recently and how often you order, the range of products you buy, how long you have been trading, and your returns history. It also includes your repayment record with us.

Part of this assessment is automated. Our systems calculate a score and a risk category for your business without human involvement. Businesses with very little trading history may not be scored at all. A member of our team reviews the result before any credit limit is approved or declined — decisions are not made by the system alone.

We do not use your location, your device, your contacts or your personal characteristics to assess creditworthiness, and we do not buy data about you from credit bureaus or telecom companies.

If you would like to know how your assessment was reached, disagree with it, or want a person to look at it again, contact us using the details in section 15 and we will review it.

7. How we share your information

We do not sell your personal information. We share it only as described here.

WhoWhat they receive, and why
Didit
Identity verification
The identity document images, selfie and liveness data captured during verification, in order to verify your identity and return the result to us.
Google
Voice processing and maps
Voice recordings you make with the voice feature, to convert them to text. Map and location data when your business location is displayed.
OneSignal
Push notifications
Your notification token and limited device information, to deliver notifications.
Our SMS provider
Messaging
Your phone number and message content, to send one-time passcodes and service messages. Where you ask us to send a customer a reminder, that customer's number and the reminder text.
Cloud hosting and storage providersThey store and process information on our behalf under confidentiality and data-protection terms. See section 13.
Distribution and financing partnersWhere you apply for or use financing, the application and identity information needed to assess and service it, and records of the orders, financing and repayments relating to your account with that partner.
Regulators, law enforcement and courtsWhere required by law, or to protect rights, safety and the integrity of our services.
A buyer or investorIn connection with a merger, acquisition, financing or sale of assets — subject to this policy.

8. How long we keep information

We keep your information for as long as your account is active and for as long as we need it to provide the App, and after that where the law requires us to keep it.

InformationHow long
Voice recordingsUp to 30 days, then deleted
Server and access logs30 days
Financial, transaction and identity-verification recordsAt least five years after your account closes or our relationship ends, as required by Pakistani financial-services and anti-money-laundering rules
Everything elseDeleted or anonymised when it is no longer needed, or on request — see section 11

9. How we protect information

We use technical and organisational measures designed to protect your information against unauthorised access, disclosure, alteration and destruction. These include encrypting all traffic between the App and our servers, encrypting identity documents and selfies where they are stored, hashing passwords so they cannot be read back, verifying that messages from our partners are genuine, limiting staff access to what each role needs, and keeping audit records of administrative actions.

No method of transmission or storage is completely secure, and we cannot guarantee absolute security. Please keep your login details confidential, and tell us straight away if you think someone else has access to your account.

10. Your rights and choices

You may:

To exercise any of these, email danish@hilalpe.com. We will respond within 30 days.

11. Deleting your account

You can ask us to delete your HilalPay account and your personal data at any time. Request account deletion →

Start a request on the page linked above, or email danish@hilalpe.com from the phone number or email address registered to your account.

We will verify the request is genuinely from you and then delete your account and personal data — including your identity documents, selfie and any voice recordings — within 30 days. We will keep only what the law requires us to keep, described in section 8, and any outstanding financing records until that financing is settled. Anything we keep for those reasons stays protected under this policy and is deleted once the required period ends.

12. Children's privacy

HilalPay is for people aged 18 or over. We do not knowingly collect information from children. If you believe a child has given us personal information, contact us and we will delete it.

13. Where your information is processed

Our servers and databases are hosted with Alibaba Cloud in Hong Kong. Identity documents and other uploaded files are stored with Amazon Web Services in the United States. Our identity-verification partner Didit processes information in the European Union. Google and OneSignal process information in the United States and other countries where they operate. Our SMS provider operates in Pakistan.

This means your information is processed outside Pakistan. Wherever it goes, we require it to be protected in line with this policy and applicable law.

14. Changes to this policy

We may update this policy from time to time. We will post the updated version at hilalpe.com/privacy and change the "Last updated" date above. If a change materially affects you, we will tell you through the App or by another direct means. Continuing to use the App after a change takes effect means you accept the updated policy.

15. How to contact us

If you have a question, a request, or a complaint about this policy or how we handle your information:

By using HilalPay, you confirm that you have read and understood this policy and agree to us collecting, using and sharing your information as described in it.