Gambia9 privacy policy

Last updated: 5 September 2026.

The short version

Gambia9 helps you update Gambian phone numbers saved in your phone.

Your contacts are read on your phone, checked on your phone, and updated on your phone. We never send your contacts to us. There is no way for us to receive them, even if we wanted to.

If you pay for the app, we ask for your own name, email, phone number and country. If you tick the optional Ping Money marketing boxes, we ask for your name and email, and for your phone number if you want SMS or WhatsApp, and we keep a record of what you agreed to so you can change your mind later.

Those two things are all the personal information we receive.

Marketing is always optional. You never have to agree to it to use or buy the app.

Who we are

Gambia9 is published by Pay365 Limited, trading as Ping Money.

Pay365 Limited is the data controller for the personal information described in this policy.

• Registered/business address: Future Business Centre Cambridge, King's Hedges Road, Cambridge, CB4 2HY, United Kingdom
• Email: support@gambia9.com
• Website: gambia9.com
• Company number: 10737836
• ICO registration number: ZA312683
• Data protection contact: support@gambia9.com

Pay365 Limited also runs the Ping Money brand. Gambia9 and Ping Money are the same company. So when this policy talks about Ping Money using your data, that is us using it internally. It is not sharing with another company.

What Gambia9 does

The Gambian regulator, PURA, is changing national phone numbers from 7 digits to 9 digits. The change takes effect on 4 September 2026.

Gambia9 looks through the contacts on your phone, finds Gambian numbers that need updating under the published plan, shows you exactly what it proposes to change, and updates only the contacts you confirm.

Our main promise: your contacts stay on your phone

This is the most important part of this policy.

• Your contacts are read on your device.
• They are analysed on your device.
• The updates are written back on your device.
• Contact names, phone numbers and contact IDs are never sent to us.

We do not have a server that accepts contact data. There is no upload button, no background sync, and no hidden copy. Our backend has an automated test that fails the build if anyone ever adds an endpoint that looks like it could receive an address book.

We also never send your contacts to analytics tools, crash reports, log files, payment providers, or any other company.

The undo record on your phone

Before Gambia9 changes any contact, it writes a record of the old number and the new number — and, where the app kept or added the old number as a second entry on the contact, the label it used for that entry. This is what makes undo possible.

• This record is stored only on your phone, in the app's own local database.
• It is never sent to us.
• The app never syncs or backs it up anywhere.
• You can delete it in the app when you no longer need to undo.

Because it holds phone numbers, we treat it as sensitive. It is never logged and never included in crash reports.

What we collect

If you use the free scan and preview

Nothing personal.

The app asks our server for two things: the current numbering rules, and the app's settings (for example, whether payment is switched on). These are plain requests for public information. They carry no name, no account, and nothing taken from your contacts.

When an update finishes, the app also tells our server that one update finished. That message contains no name, no number, no device identifier, and nothing about your contacts — not even how many were changed. It says only that an update finished, and whether the app was the iPhone version or the Android version.

From version 1.1, when an update adds old numbers back next to new ones, the app sends one more message of exactly the same kind: that such a repair finished, and on which kind of phone. Again no count, no number, and nothing about your contacts.

We keep those as counts per day: how many updates finished, and how many of them were on each kind of phone. That is the whole record — there is no row anywhere with your name on it, because nothing identifying was ever sent. We use the counts to see how many people the app is helping, and to tell whether the app works as well on Android as it does on iPhone.

There is nothing in any of this that could be traced back to you, and it is not used to track you across apps or websites.

If you buy the app

You type these in yourself, and we receive them:

• first name
• last name
• your own email address
• your own mobile number
• your country

We also record technical details about the purchase:

• platform (iOS or Android)
• app version
• market (which price list applied)
• a random installation ID that our app generates. It is a random string. It is not your device ID, not your phone number, and not linked to your identity unless you buy.
• payment provider reference and order status/history
• timestamps

Where paid unlocking is switched on, the app also sends that random installation ID on its own, to ask our server whether this installation has already paid. That check runs for people who have not bought as well as for those who have. It carries no name, no number, and nothing from your address book — only the random string the app generated for itself.

Paid unlocking is switched off at launch, so this check does not run yet.

If you tick the optional marketing boxes

If, and only if, you tick a box, we store:

• your first name and last name
• your email address
• your mobile number, if you gave one
• your country, if you chose one
• the brand you agreed to hear from (Ping Money)
• which channels you chose (email, SMS, WhatsApp)
• the exact wording you agreed to, and its version number
• the date and time
• where in the app you agreed

Why we ask for each one:

• Your name — so a message can greet you by name instead of "Dear customer".
• Your mobile number — we cannot send you an SMS or a WhatsApp message without it. If you tick either of those boxes we have to ask for the number, because agreeing to a message we have no way to send you would be meaningless.
• Your country — so we can send offers that apply where you live. Choosing it is optional.

If you only want email, your name and your email address are enough.

The boxes are unticked when you see them. Each channel is separate. You can buy the app, and use everything in it, without ticking anything.

What we deliberately do not collect

We want to be specific about this, because it matters more than any promise:

• contact names
• contact phone numbers
• contact IDs or labels
• how many contacts you have
• scan results or converted numbers
• your address book in any form
• your IMEI or device serial number
• your location

None of the above is used for anything, including fraud checks.

Why we are allowed to use your information

Under UK GDPR we need a lawful basis for each use.

Our legitimate interest is running the service safely and preventing payment fraud. We have kept this to the smallest set of signals we could. We do not use anything from your address book for it.

How long we keep things

• Order and payment records — six years from the end of the accounting period they fall in. This is the retention period for company records under the Companies Act 2006 and for VAT records under the Value Added Tax Regulations 1995.
• Marketing consent records — kept while your consent is active, and for six years after you withdraw it, so we can show what you agreed to and when if the question is ever raised.
• Suppression records — when you withdraw consent, we keep a small record of your email address, brand and channel. This is what stops us adding you back to a campaign by mistake. We keep it for as long as we run marketing. Keeping it is how we honour your withdrawal, not a way of ignoring it.
• The undo record on your phone — stays on your phone until you delete it, or until you delete the app.

Who else is involved

A few companies help us run the service, and each one gets only what it needs. Apple and Google distribute the app and, where purchases exist, take the payment under their own privacy policies. Laravel Cloud runs our server and database in the United Kingdom. Brevo sends Ping Money messages to people who opted in, and receives only the details those people gave us. We put a data processing agreement in place with each of these companies before it handles any of your information.

None of these companies ever receive your contacts, because we never have them.

Sending information outside the UK

Our servers are in the United Kingdom, so the information you give us stays here. Pay365 Limited is a UK company, and there is no transfer to explain for the data we hold ourselves.

Brevo, which sends Ping Money messages to people who opted in, is in the European Union. The UK government has decided the EU provides an adequate level of protection, so no additional safeguard is needed for that.

Apple and Google act as sellers in their own right and apply their own policies and transfer safeguards; we do not choose where they store the data they collect as the seller.

Your rights

Under UK GDPR you can ask us to:

• give you a copy of the personal information we hold about you
• correct it if it is wrong
• delete it, where we do not need to keep it by law
• stop or limit how we use it
• send it to you or another provider in a portable format
• object to us using it under legitimate interests
• withdraw consent to marketing at any time

Email support@gambia9.com and tell us what you want. We will reply within one month. There is no charge.

Please note: we cannot give you a copy of your contacts, because we do not have them. Everything about your contacts stays on your phone, under your control.

Withdrawing marketing consent

You can stop marketing at any time. Any of these works:

• click the unsubscribe link in any email
• reply STOP to an SMS
• email support@gambia9.com

When you withdraw, we mark your consent as withdrawn and add a suppression record so that no future campaign can pick you up again by accident.

Withdrawing marketing does not affect your purchase, your access to the app, or your right to support.

Complaints

Please tell us first, at support@gambia9.com. We would rather fix it.

You can also complain to the UK's data protection regulator:

Information Commissioner's Office Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF Helpline: 0303 123 1113 ico.org.uk

Data protection in The Gambia

Gambia9 is made for people in The Gambia and for Gambians abroad. Pay365 Limited is a UK company, so this policy is written around UK data protection law, and the standards it sets — telling you what we collect, collecting as little as we can, and letting you see, correct or delete it — apply to you wherever you live.

We have not yet had this policy reviewed against The Gambia's own data protection law, and we are not claiming here that it meets requirements we have not checked. That review is in hand. If you are in The Gambia and something in this policy conflicts with your rights under Gambian law, those rights are not reduced by anything written here — write to support@gambia9.com and we will put it right.

Children

Gambia9 is not aimed at children under 13. We do not knowingly collect personal information from children under 13. If you believe a child has given us personal information, email support@gambia9.com and we will delete it.

Permissions the app asks for

• Read contacts — so the app can find Gambian numbers that need updating.
• Write contacts — asked for only when you have confirmed an update. If you never confirm one, the app never needs it. It is used to replace the numbers you approved, to keep or add the old number as a second entry labelled "old", and to remove an entry the app itself added — nothing else.
• Internet — so the app can fetch the current numbering rules and its settings.

You can refuse or later revoke these in your phone's settings. If you refuse contact access, the app cannot do its job, but nothing is sent anywhere.

Changes to this policy

If we change this policy, we will update the version at gambia9.com and change the date at the top. If the change is significant, we will tell you in the app before it takes effect.

Contact us

Pay365 Limited (trading as Ping Money) Future Business Centre Cambridge, King's Hedges Road, Cambridge, CB4 2HY, United Kingdom support@gambia9.com