Privacy Policy

1. Collection of Personal Data

We collect the following types of personal data:

Types of data collected:

• Identification information: first name, last name, date of birth, passport number or other identification document, residential address;
• Contact information: email address, phone number, mailing address;
• Financial information: bank details, cryptocurrency wallet information, transaction history;
• Technical information: IP address, browser type, operating system, device data, cookies and similar technologies;
• Transaction information: payment details, amounts, currencies, wallet addresses, transaction hashes;
• Verification information: documents confirming identity, address and source of funds (KYC/AML documents);
• Communication information: correspondence with our support service, phone call records.

Data collection methods:

• Directly from you when registering an account and using our services;
• Automatically when using our website and mobile applications;
• From third parties, including payment systems, banks and verification services;
• Through cookies and similar tracking technologies.

2. Use of Personal Data

We use your personal data for the following purposes:

Purposes of use:

• Providing and improving our cryptocurrency payment processing services;
• Verifying your identity and complying with KYC/AML requirements;
• Processing transactions and managing your account;
• Preventing fraud, money laundering and other illegal activities;
• Complying with legal and regulatory requirements;
• Communicating with you regarding your account and our services;
• Sending important notifications and updates;
• Analyzing the use of our services to improve functionality;
• Marketing communications (only with your consent);
• Ensuring the security of our systems and protection against cyberattacks.

Legal basis for processing:

• Performance of a contract with you;
• Compliance with legal obligations;
• Protection of our legitimate interests;
• Your consent (where required).

3. Sharing Personal Data with Third Parties

We may share your personal data with the following categories of recipients:

Data recipients:

• Verification service providers and KYC/AML checks;
• Banks and financial institutions for payment processing;
• Cryptocurrency exchanges and wallets for transaction execution;
• Cloud service and hosting providers;
• Analytics and monitoring services;
• Legal and consulting firms;
• Law enforcement and regulators (when legally required);
• Other companies in the context of corporate reorganization or merger.

4. Data Security

We implement comprehensive security measures to protect your personal data:

Security measures:

• Data encryption in transit (TLS/SSL) and at rest;
• Multi-layer authentication and authorization system;
• Cold storage of cryptocurrency assets;
• Regular security audits and penetration testing;
• Limited access to personal data only for authorized personnel;
• Monitoring and detection of suspicious activity;
• Data backup and disaster recovery plans;
• Staff training on security and privacy issues.

5. Data Retention

We retain your personal data for the period necessary to achieve the purposes set out in this Policy or in accordance with applicable law:

Retention periods:

• Account data: for the entire duration of your account and 7 years after its closure;
• Financial data and transactions: minimum 7 years in accordance with AML/CFT requirements;
• KYC/AML documents: minimum 7 years after the end of business relationships;
• Logs and technical data: up to 2 years;
• Marketing data: until you withdraw your consent or 3 years from the last interaction.

6. Your Rights

In accordance with applicable data protection laws, you have the following rights:

User rights:

• Right of access: you may request a copy of your personal data that we hold;
• Right to rectification: you may request correction of inaccurate or incomplete data;
• Right to erasure: you may request deletion of your data under certain circumstances;
• Right to restriction of processing: you may request restriction of processing of your data;
• Right to data portability: you may request transfer of your data to another service provider;
• Right to object: you may object to processing of your data for certain purposes;
• Right to withdraw consent: if processing is based on your consent, you may withdraw it at any time;
• Right to lodge a complaint: you may file a complaint with a data protection supervisory authority.

7. Cookies and Similar Technologies

We use cookies and similar technologies to improve your experience using our services:

Types of cookies used:

• Essential cookies: required for the website to function and cannot be disabled;
• Functional cookies: improve website functionality and remember your preferences;
• Analytics cookies: help us understand how users interact with our website;
• Marketing cookies: used to track visitors and show relevant advertising (only with your consent).

8. International Data Transfers

Your personal data may be transferred and stored in countries outside your jurisdiction. We ensure adequate protection of your data in such transfers:

Safeguards:

• Use of standard contractual clauses approved by regulators;
• Compliance with international data protection standards;
• Regular risk assessments and security audits;
• Ensuring compliance with GDPR and other applicable data protection laws.

9. Protection of Minors' Data

Our services are intended for persons over 18 years of age (or the age of majority in your jurisdiction). We do not knowingly collect personal data from minors. If we learn that we have collected data from a minor without parental consent, we will immediately delete such information.

10. Changes to Privacy Policy

We may periodically update this Privacy Policy. We will notify you of significant changes by email or through a notice on our website. We recommend that you periodically review this page to familiarize yourself with the current version of the Policy.

Effective date: January 15, 2024

11. Contact Information

If you have any questions, comments or requests regarding this Privacy Policy or the processing of your personal data, please contact us:

Contact details:

• Email: support@arcanumpay.com
• Phone: +7 (918) 575-12-56
• Address: 112 Zorge St, Suite 1, Moscow
• Legal entity: Arcanum Pay LLC
• Tax ID: 931101685910