Privacy Policy
[TODO: last updated date]
1. Data we collect
When you use the website and the Service, we may collect: contact details (when you reach out to the manager), company data provided during KYB, technical data (IP address, browser type, cookies), and transaction data required to process payments.
2. Purposes and legal bases (GDPR)
For individuals in the EEA/UK, we process personal data under GDPR on the following bases: performance of a contract (providing the payment gateway), legal obligation (AML/CFT and KYC/KYB requirements), legitimate interest (service security and improvement), and consent (non-essential cookies and marketing). [TODO: confirm legal bases with DPO/counsel]
3. Data sharing
Data may be shared with infrastructure providers (hosting, blockchain analytics) to the extent necessary to deliver the Service, and with competent authorities where required by law. We do not sell personal data. Where data is transferred outside the EEA, appropriate safeguards are applied. [TODO: list recipient categories after legal review]
4. Retention and security
We apply multi-layer encryption and organisational safeguards. Retention periods are determined by anti-money-laundering legislation and internal policies; data subject to AML obligations cannot be deleted on request before those periods expire. [TODO: specify retention periods]
5. Your rights
You may request access, rectification, erasure, restriction, portability, or object to processing by contacting the manager on Telegram: @crypto_payments_manager. EEA/UK residents may also lodge a complaint with their supervisory authority. [TODO: add DPO contact if appointed]
Note
This material is for informational purposes only and does not constitute legal advice.