Application: HAL Pay — e-Wallet
Provider: Houng Ah Loun Payment Solution Sole Co., Ltd.
Effective Date: 18 May 2026
Last Updated: 18 May 2026
Houng Ah Loun Payment Solution Sole Co., Ltd. ("HAL Pay," "we," "us," or "our") operates the HAL Pay mobile application (the "App"), an electronic wallet ("e-Wallet") service that enables users in the Lao People's Democratic Republic ("Laos") to make digital payments, transfers, and related financial transactions.
This Privacy Policy describes how we collect, use, disclose, store, and protect your personal information when you download, register for, or use the HAL Pay App and related services (collectively, the "Services"). By creating an account or using the App, you acknowledge that you have read and understood this Privacy Policy.
We are committed to handling your personal information in accordance with the Law on Electronic Data Protection of the Lao PDR, the regulations of the Bank of the Lao PDR governing electronic payment services, and internationally recognized data protection principles.
To provide a secure e-Wallet service and to comply with Know-Your-Customer ("KYC"), anti-money-laundering ("AML"), and counter-terrorism-financing ("CFT") obligations, we collect the following categories of information:
| Category | Examples |
|---|---|
| Identity Information | Full name (in Lao and/or English), date of birth, gender, nationality, place of birth |
| Contact Information | Mobile phone number, email address, residential address |
| Government-Issued Identification (KYC) | National ID number, passport number, family book, driver's license, or other accepted ID document; photograph of the ID document; selfie/live photo for identity verification; signature |
| Account Credentials | Username, password (stored in hashed form), PIN, security questions, recovery information |
| Communications | Customer-support messages, complaint records, survey responses |
When you use the App, we may automatically collect limited technical information necessary for security and fraud prevention, such as device model, operating system version, App version, language settings, time zone, IP address, and crash logs. We do not collect precise GPS location unless you explicitly enable an optional feature that requires it.
We may receive information about you from authorized partners, including banks, telecommunications providers, government KYC verification services, credit-reference agencies, and merchants, in each case for the purpose of verifying your identity, processing transactions, or preventing fraud.
We use your personal information only for legitimate, specified purposes, including to:
We process your personal information on one or more of the following legal grounds:
The App requests the following device permissions only when they are needed to deliver a feature. You may refuse or revoke any optional permission through your device settings.
| Permission | Why We Request It | Required / Optional |
|---|---|---|
| Camera | To capture photos of your ID document and a live selfie for KYC verification; to scan QR codes for payment | Required for KYC; Optional for QR pay |
| Photos / Storage | To upload ID documents or transaction receipts | Optional |
| Notifications | To send transaction alerts, OTPs, and security notices | Recommended |
| Contacts | To help you send money to people in your contact list (only contacts you select are processed; the full contact list is not uploaded) | Optional |
| Phone / SMS | To auto-fill one-time passwords (OTPs) sent by SMS | Optional |
| Biometric (Fingerprint / Face ID) | To allow quick and secure App login or transaction authorization. Biometric data never leaves your device. | Optional |
We retain your personal information only for as long as is necessary to fulfill the purposes set out in this Policy, including any legal, accounting, or reporting requirements. Specifically:
We implement administrative, technical, and physical safeguards designed to protect your personal information against unauthorized access, alteration, disclosure, or destruction. These safeguards include:
Despite these measures, no method of electronic transmission or storage is completely secure. You are responsible for keeping your login credentials, PIN, and OTP confidential and for notifying us immediately of any suspected unauthorized use of your account.
Subject to applicable law, you have the right to:
To exercise any of these rights, please contact us using the details in Section 14. We may need to verify your identity before fulfilling your request and will respond within the time limits required by law.
HAL Pay is intended for users aged 15 years or older who can legally enter into a contract under Lao law. We do not knowingly collect personal information from children below this age. If we become aware that we have collected personal information from a child without verifiable parental consent, we will delete such information promptly. Parents or guardians who believe their child has provided personal information to us should contact us immediately.
Your personal information is primarily stored on servers located in Laos. Where we use cloud-hosting or service providers based outside Laos, we ensure that appropriate safeguards (such as contractual data-protection clauses) are in place to protect your information consistent with this Policy and applicable law.
The App may contain links to or integrations with third-party websites, merchants, or services (for example, billers, e-commerce partners, or app-store providers such as Apple App Store and Google Play). This Privacy Policy does not apply to those third parties. We encourage you to read their privacy policies before providing them with personal information.
We use limited analytics and crash-reporting tools (such as Google Firebase) to understand App stability and performance. These tools collect aggregated, pseudonymized data and are bound by their own privacy terms.
We may update this Privacy Policy from time to time to reflect changes in our practices, technology, legal requirements, or other reasons. When we make material changes, we will notify you through the App or by other reasonable means and update the "Last Updated" date above. Your continued use of the Services after the changes take effect constitutes your acceptance of the revised Policy.
If you have any questions, concerns, or requests regarding this Privacy Policy or our handling of your personal information, please contact our Data Protection Officer:
We will acknowledge your request within a reasonable period and respond substantively within the time required by applicable law.