1. Purpose

This Account Deletion Policy explains how customers can request deletion of their account from the LAKHOO PAY mobile application and how the Company handles customer information following an account deletion request.

As a regulated money exchange and remittance business, the Company is required to maintain certain customer, identification, transaction, financial, and compliance records for specified periods. Therefore, deleting a mobile application account does not necessarily result in the immediate deletion of all information associated with the customer.

2. Scope

This policy applies to customers who have registered or created an account through the Company’s mobile application and covers information associated with the customer’s application account, including personal information, account information, KYC information, transaction information, beneficiary information, and application-related data.

3. How to Request Account Deletion

Customers may request deletion of their mobile application account by:

• Using the Delete Account option available within the mobile application, where provided; or
• Contacting the Company’s Customer Support through the contact details provided in the application or on the Company’s official website.

The Company may require the customer to complete an identity verification process before processing the request to ensure that the request has been made by the legitimate account holder.

4. Account Deletion Process

After receiving an account deletion request, the Company will review the account to determine whether there are any outstanding transactions, pending remittances, refunds, disputes, investigations, regulatory requirements, or other matters that require the account or associated information to be retained.

Where deletion is permitted, the Company will delete or anonymize information that is no longer required to be retained.

Where information is required to be retained under applicable laws, regulations, AML/CFT requirements, financial regulations, audit requirements, or other legitimate obligations, such information will be securely retained for the applicable retention period.

5. Information That May Be Deleted

Subject to applicable legal and regulatory requirements, the Company may delete or anonymize information such as:

• Mobile application login credentials and account information.
• Application preferences and settings.
• Non-essential profile information.
• Device-related information where retention is no longer required.
• Marketing preferences.
• Other application-related information that is not required to be retained.

6. Information That May Be Retained

As a money exchange and remittance company, the Company may be legally or regulatorily required to retain certain information after an application account has been deleted.

This may include:

• Customer identification information.
• KYC and customer due diligence records.
• Identification documents submitted for verification.
• Customer risk assessment information.
• Transaction and remittance records.
• Sender and beneficiary information.
• Payment and settlement records.
• AML/CFT monitoring records.
• Sanctions and screening records.
• Fraud detection and investigation records.
• Suspicious transaction or regulatory reporting records, where applicable.
• Customer complaints and dispute records.
• Accounting and financial records.
• Audit records.
• Information required by regulatory authorities.
• Information necessary to establish, exercise, or defend legal claims.

Such information will be retained only for the period required or permitted by applicable laws and regulations.

7. Regulatory and AML/CFT Requirements

Because the Company provides money exchange and/or remittance services, certain customer and transaction information may be subject to mandatory retention requirements.

An account deletion request will not override the Company’s obligations relating to:

• Customer identification and KYC.
• Customer due diligence.
• Anti-Money Laundering (AML).
• Counter-Terrorist Financing (CFT).
• Sanctions compliance.
• Fraud prevention.
• Regulatory reporting.
• Financial and transaction record keeping.
• Regulatory inspections and audits.

Accordingly, information required for these purposes may remain securely stored after the customer’s mobile application account has been deleted.

8. Pending Transactions

Account deletion may not be completed immediately if the customer has:

• A pending money transfer or remittance.
• A pending exchange transaction.
• A pending refund.
• An unresolved transaction dispute.
• An outstanding payment or financial obligation.
• An ongoing fraud, AML/CFT, sanctions, or compliance review.
• A legal or regulatory matter involving the customer or transaction.

The Company may complete or resolve such matters before processing the deletion request to the extent permitted by applicable requirements.

9. Completed Transactions

Deleting an account does not delete or invalidate transactions that have already been completed.

Transaction records may continue to be retained for the period required by applicable laws, regulations, accounting requirements, AML/CFT obligations, audit requirements, or the Company’s legitimate business requirements.

Previously completed transactions may therefore remain part of the Company’s official records even after the mobile application account has been deleted.

10. Uninstalling the Mobile Application

Uninstalling the mobile application from a customer’s mobile device does not delete the customer’s account.

Customers who wish to permanently delete their account must submit an account deletion request through the application or contact the Company’s Customer Support.

11. Effect of Account Deletion

Once the account deletion process has been completed:

• The customer will no longer be able to access the deleted mobile application account.
• The customer’s application profile may be removed.
• Saved application preferences may be deleted.
• Non-required personal information may be deleted or anonymized.
• Previously completed transaction records may continue to be retained where required.
• Legally required KYC, AML/CFT, financial, regulatory, and transaction records may remain securely stored.
• The deletion of the application account does not cancel or reverse previously completed transactions.

12. Backup and Disaster Recovery Copies

Certain information may continue to exist temporarily in secure backup or disaster recovery systems after account deletion.

Backup copies are maintained for business continuity, security, disaster recovery, and regulatory purposes and will be deleted or overwritten in accordance with the Company’s applicable backup retention and data management procedures.

13. Third-Party Service Providers

The Company may use authorized third-party service providers to support services such as:

• Identity verification.
• Payment processing.
• Remittance processing.
• Fraud detection.
• Sanctions screening.
• AML/CFT monitoring.
• Cloud hosting.
• Information security.
• Customer communication.

Where applicable, such service providers may be required to retain certain information to comply with legal, regulatory, contractual, security, or operational requirements.

The Company will take appropriate measures to ensure that customer information is handled securely and in accordance with applicable requirements.

14. Identity Verification

To protect customers from unauthorized account deletion, the Company may request additional information or verification before processing an account deletion request.

The Company may refuse or delay a deletion request where it cannot reasonably verify the identity of the requester.

15. Re-registration After Deletion

A customer who wishes to use the Company’s mobile application after account deletion may be required to register again and complete the applicable customer identification and KYC verification procedures.

Previous account deletion does not guarantee that a new account will be approved.

The Company may restrict or refuse a new account where required by applicable laws, regulations, AML/CFT requirements, sanctions requirements, internal policies, or other legitimate reasons.

16. Data Security

The Company maintains appropriate technical and organizational security measures to protect customer information against unauthorized access, alteration, disclosure, loss, or destruction.

Information retained following account deletion will continue to be protected through the Company’s applicable information security, access control, encryption, monitoring, and data protection measures.

17. Withdrawal of Deletion Request

Where technically and operationally possible, customers may contact Customer Support to request cancellation of an account deletion request before the deletion process has been completed.

Once information has been permanently deleted or anonymized, it may not be possible to recover it.

18. Data Retention and Final Deletion

Information that is not subject to a legal, regulatory, contractual, security, or legitimate business retention requirement will be deleted or anonymized within a reasonable period following completion of the account deletion process.

Information subject to mandatory retention will be securely retained until the applicable retention period expires. Following expiry of the applicable retention period, the information will be securely deleted or anonymized in accordance with the Company’s data retention procedures.