Last Updated: January 2025
1. Introduction
Welcome to Saman Hawala. We are committed to protecting your privacy and ensuring the security of your personal information. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you use our hawala and money transfer services.
As a financial services provider, we handle sensitive personal and financial data with the utmost care and in full compliance with applicable laws and regulations. By using our services, you agree to the collection and use of information in accordance with this policy.
2. Information We Collect
2.1 Personal Information
We may collect the following personal information:
- Full name and contact details (phone number, email address)
- Date of birth and nationality
- Government-issued identification (national ID, passport, or equivalent)
- Residential and business addresses
- Financial information including bank account or wallet details
- Transaction history, amounts, and beneficiary details
- Source of funds declarations (as required by AML regulations)
2.2 Automatically Collected Information
- IP address and device information
- Browser type and operating system
- Website usage data and analytics
- Cookies and similar tracking technologies
3. How We Use Your Information
We use the collected information for the following purposes:
- Processing and completing your money transfer transactions
- Verifying your identity (KYC – Know Your Customer) as required by law
- Complying with Anti-Money Laundering (AML) and Counter-Terrorism Financing (CTF) regulations
- Communicating with you about your transfers and account activity
- Detecting, preventing, and investigating fraudulent transactions
- Complying with legal and regulatory reporting obligations
- Improving our services and customer experience
- Sending service-related notifications and updates
- Maintaining security and preventing misuse of our services
4. Information Sharing and Disclosure
We may share your information with:
- Correspondent Agents & Partners: Trusted hawala agents and financial partners required to complete your transfer
- Regulatory & Government Authorities: As required by law, including financial intelligence units, central banks, and law enforcement agencies
- Payment Service Providers: Third-party companies that assist with payment processing and settlement
- Legal Compliance: When required by law, court order, or legal process
- Fraud Prevention Services: To screen transactions and prevent financial crime
We do not sell your personal information to third parties for marketing purposes.
5. Regulatory Compliance
Saman Hawala operates in full compliance with applicable financial regulations, including Anti-Money Laundering (AML) laws, Know Your Customer (KYC) requirements, and Counter-Terrorism Financing (CTF) obligations. We are required by law to verify the identity of our customers and to report suspicious transactions to the relevant authorities. This may involve retaining your personal and transaction data for extended periods as mandated by regulation.
6. Data Security
We implement appropriate technical and organizational measures to protect your personal information against unauthorized access, alteration, disclosure, or destruction. All financial data is handled with bank-grade security protocols. However, no method of transmission over the internet is 100% secure, and we cannot guarantee absolute security.
7. Data Retention
We retain your personal information for as long as necessary to fulfill the purposes outlined in this policy, comply with legal and regulatory obligations (which may require retention for 5–10 years for financial records), resolve disputes, and enforce our agreements.
8. Your Rights
You have the right to:
- Access your personal information we hold
- Request correction of inaccurate data
- Request deletion of your data (subject to legal and regulatory requirements)
- Opt-out of marketing communications
- Withdraw consent for data processing where consent is the legal basis
Please note that certain data cannot be deleted due to mandatory regulatory retention requirements. To exercise these rights, please contact us using the information provided below.
9. Cookies Policy
We use cookies and similar technologies to enhance your browsing experience, analyze website traffic, and understand user preferences. You can control cookie settings through your browser, though disabling cookies may affect website functionality.
10. International Data Transfers
As we facilitate international money transfers, your information may be transferred to and processed in different countries. We ensure appropriate safeguards are in place to protect your information during such transfers, and all cross-border data sharing complies with applicable data protection laws.
11. Children's Privacy
Our services are not intended for individuals under 18 years of age. We do not knowingly collect personal information from minors. If you believe we have collected information from a child, please contact us immediately.
12. Changes to This Privacy Policy
We may update this Privacy Policy periodically to reflect changes in our practices or legal requirements. We will notify you of significant changes by posting the updated policy on our website with a revised "Last Updated" date.
13. Terms of Service
13.1 Service Agreement
By using Saman Hawala services, you agree to our terms and conditions. We provide informal value transfer (hawala) and money remittance services. All transactions must comply with applicable laws and regulations.
13.2 Customer Obligations
Customers must provide accurate and truthful information, including valid identification. You agree not to use our services for money laundering, terrorist financing, fraud, or any other illegal activity. We reserve the right to refuse or cancel any transaction suspected of being linked to illegal activity.
13.3 Prohibited Transactions
We do not process transactions that violate international sanctions, are intended to fund illegal activities, involve undisclosed third parties, or breach any applicable law or regulation.
13.4 Liability
While we strive for accuracy and timeliness, we are not liable for delays caused by regulatory holds, correspondent agent issues, inaccurate beneficiary information provided by the sender, or circumstances beyond our control.
13.5 Payment Terms
Payment must be made in full before a transfer is processed. Our fees and applicable exchange rates will be disclosed to you prior to completing any transaction.
14. Contact Information
For privacy-related inquiries or to exercise your rights, please contact us:
Company: Saman Hawala
Email: info@samanhawala.com
Phone Numbers:
- Iraq (+964):
- Kurdish Language: 0750 203 0280
- Arabic Language: 0771 136 2525
Address: Iraq, Erbil