Privacy Policy

Pay.Partners (“Pay.Partners”, “we”, “our”, “us”) – a professional software development committed to upholding the highest standards of development, testing, technical support and activities related to online payment solution of media buying, which acts as a platform for providing services to third parties (issuer, crypto providers) and your relationship with Pay.Partners, who is responsible for the collection, processing and use of your personal data within the meaning of Art. 4 No. 7 GDPR on the website https://pay.partners/ (the “Website”).

Definitions

Data Controller – Pay.Partners;

Personal data – any information relating to an identified or identifiable natural person (“data subject”); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person;

Processing – any operation or set of operations performed on personal data or sets of personal data, whether or not by automated means, such as collecting, recording, organizing, structuring, storing, adapting or modifying, retrieving, consulting, using, disclosing by transmission, disseminating or otherwise making available, matching or combining, restricting, deleting or destroying;

GDPR – Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (General Data Protection Regulation);

Website – website run by us at https://pay.partners/;

User – any person visiting the Website or using the services or functionalities described in this Privacy Policy.

Acceptance of This Privacy Policy

By using our Website (whether or not you register or create any kind of account with us), you agree to accept the terms set forth in this Privacy Policy as well as in the Terms & Conditions. Anyone that does not agree to the terms of this Privacy Policy and the Terms & Conditions, should not use Our Website. You agree that your only recourse should you not agree to the terms of this Privacy Policy and the Terms & Conditions shall be to discontinue using our Services and visiting our Website. By using our Services, you consent to having your Personal Data transferred to and processed by us and our third party vendors.

Consent

By using our Website and/or Services you consent to our Privacy Policy, as well as the limitation of liability, dispute resolution procedures, refund policy and all the other Terms & Conditions that form a binding agreement between you and us.

Privacy Statement

We shall be considered a data owner and Data controller in relationships with Data Subjects. We acknowledge the privacy of natural persons and make efforts to protect them against any unlawful Processing by applying relevant technical and organizational measures to protect Personal Data of natural persons in accordance with the effective legislation. Although we will make reasonable efforts to ensure safe Processing, we cannot guarantee it to be 100% secure and risk-free and you acknowledge and accept such risks.

We process Personal Data in a way that assures appropriate level of security, including protection against unauthorized Processing, destruction, accidental loss, or damage, while applying suitable organizational and technical measures under industry standards and in compliance with the following principles:
(1) lawfully, fairly and transparently;
(2) Processing is specified, explicit and only for legitimate purposes; Processing is adequate, relevant and limited to necessary purpose; accurate and kept up to date; limitation of the storage for periods not longer than necessary; Processing is done and the Personal Data is held in a manner that ensures appropriate security of the Personal Data.

When it comes to Processing, we will not discriminate against Data Subject rights.

We do not knowingly process Personal Data that relates to, or reveals, racial or ethnic origin, political opinions, religion or philosophical beliefs, trade union membership, genetic or biometric data, or data concerning the health, sex life or sexual orientation of the natural person.

We apply the following principles in order to protect your privacy: (a) we will not sell or lease your Personal Data to third parties; and (b) any Personal Data that you provide to us will be secured with industry-standard safety protocols and technology.

Purpose and Legal Basis for Processing

We process personal data based on one or more of the following legal bases:

1. Consent
We may process your personal data if you have given us explicit consent to use it for a specific purpose. Withdrawing your consent will not affect the lawfulness of any processing based on consent before its withdrawal. Consent must be freely given, informed, and unambiguous, and can be withdrawn at any time.

2. Performance of a Contract
We process your personal data when it is necessary to fulfill our contractual obligations to you. This includes using your data to provide services or products you have requested or taking necessary steps prior to entering into a contract. Processing is essential for performing or entering into a contract.

3. Legal Obligations
We may process your personal data where required to comply with legal obligations. This includes fulfilling statutory duties, cooperating with law enforcement, responding to regulatory authorities, or complying with court orders.

4. Vital Interests
We may process your personal data when it is necessary to protect the vital interests of yourself or others. This often applies in emergency situations involving health or safety.

5. Public Task or Official Authority
We may process personal data when necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in us.

6. Legitimate Interests
We may process personal data based on our legitimate interests or those of a third party, provided this does not override your rights and freedoms. This includes processing data for marketing, fraud prevention, or business operations.

Links to Other Websites

The Website may contain links to other websites of interest. However, once you have used these links to leave the Website, you should note that we do not have any control over that other website. Therefore, you agree to accept such risks and not hold us responsible for the protection and privacy of any information which you provide while visiting such sites and you understand such sites are not governed by this Privacy Policy. You should exercise caution and look at the privacy statement applicable to the website in question.

Response Timing and Format

We shall respond to the verifiable consumer request within forty-five (45) days of its receipt. If we require more time, we will inform the Data Subject of the reason and extension period in writing. The response is free of charge unless it is excessive, repetitive, or manifestly unfounded.

Cross-Border Data Transfers

In certain instances, personal data may be transferred to jurisdictions outside the country of residence of the data subject, including to jurisdictions that may not offer an equivalent level of data protection. In such cases, we take appropriate steps to safeguard personal data, including:

Standard Contractual Clauses (SCCs): We may implement SCCs approved by the European Commission to ensure that personal data transferred outside of the European Economic Area (EEA) is afforded an equivalent level of protection.
Adequacy decisions: Where applicable, we may rely on adequacy decisions issued by the relevant data protection authorities to transfer personal data to jurisdictions deemed to provide an adequate level of protection.
Binding Corporate Rules (BCRs): In some instances, we may rely on BCRs for intra-group transfers of personal data, ensuring that consistent data protection standards are adhered to across our global operations.

We ensure that adequate safeguards are in place to protect your personal data when it is transferred to another jurisdiction.

Retention Period

Your Personal Data will be kept for as long as is necessary to provide you with the requested service. When your Personal Data is no longer necessary to deliver the requested service, the Company will delete it as soon as possible, unless retaining your Personal Data is required by law for a certain period of time (e.g., for accountancy records).

Age Limitations

We have no official right to collect any private information from persons who are not 18 yet. It is strictly prohibited to the Users under 18 to use Our Website and any of the Services offered by Our Company. As soon as We find out that the information presented by the User is not eligible because of the age limits, it will promptly be erased. We bear no responsibility in case if You are not old enough to use the Website. You must be of legal age to be in line with Our Privacy Policy, as well as with Our Terms and Conditions.

Alert Us in case one of Your children under 18 is using Our Website trying to get access to our services. We’ll take measures to block access to Our Website from Your IP address. All affiliate websites cooperating with Our Company will be blocked for your child as well.

Your Rights

According to the EU/EEA law (General Data Protection Regulation) you have various rights regarding your personal data.

Your Rights Under EU/EEA laws (GDPR)

Right to acknowledgement and access
You have the right to receive confirmation from Us at any time as to whether personal data relating to you will be processed. If this is the case, you have the right to request from us free of charge information about the personal data stored about you together with a copy of this data.

If personal data are transferred to a third country or an international organization, you have the right to be informed of the appropriate guarantees in accordance with GDPR in connection with the transfer.

Right to correction
You have the right to request Us to correct any inaccurate personal data concerning you without delay.

Right for cancellation (“Right for oblivion”)
As a pursuant under GDPR, you have the right to demand that we delete personal data concerning you without delay, and we are obliged to delete personal data without delay if one of the following reasons applies:
1. personal data are no longer necessary for the purposes for which they were collected or otherwise processed.
2. you file an objection to the processing pursuant to GDPR, and there are no overriding legitimate grounds for the processing, or you file an objection to the processing pursuant under conditions of GDPR.
3. you withdraw your consent, on which the processing was based pursuant according to GDPR, and there is no other legal basis for the processing.
4. the deletion of personal data is necessary to fulfill a legal obligation under Union law or the law of the Member States to which we are subject.

Right to limitation of processing
You have the right to request Us to restrict processing if one of the following conditions is met:
1. you dispute the accuracy of your personal data for a period of time that enables us to verify the accuracy of your personal data;
2. the processing is unlawful, and you have refused to delete the personal data and have instead requested the restriction of the use of the personal data;
3. We no longer need the personal data for the purposes of processing, but you do need the data to assert, exercise or defend legal claims, or
4. you have filed an objection against the processing pursuant according to GDPR, as long as it is not yet clear whether the justified reasons of our company outweigh yours.

Right to transferability of data
You have the right to receive the personal data concerning you that you have provided to us in a structured, current and machine-readable format, and you have the right to transmit this data to another person in charge without our interference, provided that
1. processing is based on consent or on a contract pursuant according to conditions of GDPR and US data protection laws.
2. processing is carried out using automated methods. When exercising your right to data transferability in accordance with paragraph 1, you have the right to request that the personal data be transferred directly by us to another person responsible, insofar as this is technically feasible.

Right of objection
You have the right to object at any time, for reasons arising from your particular situation, to the processing of personal data concerning you on the basis of GDPR and US data protection laws; this also applies to profiling based on these provisions. We no longer process personal data unless we can prove compelling grounds for processing that outweigh your interests, rights and freedoms, or the processing serves to assert, exercise or defend legal claims.

If We process personal data for direct marketing purposes, you have the right to object at any time to the processing of personal data concerning you for the purpose of such advertising.

You have the right to object to the processing of personal data concerning you, for scientific or historical research purposes or for statistical purposes in accordance with GDPR and US data protection laws, for reasons arising from your particular situation, unless the processing is necessary to fulfill a task in the public interest.

Automated decisions including profiling
You have the right not to be subject to a decision based exclusively on automated processing – including profiling – that has legal effect against you or significantly impairs you in a similar manner. An automated decision making based on the collected personal data does not take place.

Right to revoke consent under data protection law
You have the right to revoke your consent to the processing of personal data at any time.

Right of appeal to a supervisory authority
You have the right of appeal to a supervisory authority.

In particular, if you have EU/EEA residentship, and have a concern about our practices concerning the processing of Personal Data that we are not able to resolve, you have the right to lodge a complaint with the data protection authority where you reside or in which you work, or in which the alleged infringement occurred, each as applicable, or by contacting the authority for such issues, at https://edpb.europa.eu/about-edpb/about-edpb/members_en.

If you wish to assert any of these rights, please contact us at [email protected]. We may require verification of identity to process your request.

Markets in Crypto-Assets Regulation (MiCA).

Some of our partners operate under MiCA (European Union regulation that creates a comprehensive legal framework for crypto-assets across the EU. It governs how crypto-assets are issued, traded, and handled by service providers, with the goal of protecting consumers, ensuring market integrity, and supporting innovation).

As part of their regulatory obligations under MiCA, these partners may collect, process, or verify certain personal data (such as identity documents, wallet addresses, or transaction history, etc.) to ensure compliance with legal and anti-money laundering (AML) requirements.

Where necessary, we may share limited personal data with trusted third-party partners who are regulated under MiCA, solely for the purpose of enabling crypto-related services and meeting legal obligations.

Our partners under MiCA meet strict data protection standards and ensure that any data sharing is carried out in accordance with applicable privacy laws, including the General Data Protection Regulation (GDPR).

CAN-SPAM Act

The CAN-SPAM Act is a law that sets the rules for commercial email, establishes requirements for commercial messages, gives recipients the right to have emails stopped from being sent to them, and spells out tough penalties for violations.

We collect your email address in order to:

• Send information, respond to inquiries, and/or other requests or questions;
• Process orders and to send information and updates pertaining to orders;
• We may also send you additional information related to your product and/or service.

To be in accordance with CAN SPAM we agree to the following:

• NOT use false, or misleading subjects or email addresses;
• Identify the message as an advertisement in some reasonable way;
• Include the physical address of our business or site headquarters;
• Monitor third party email marketing services for compliance, if one is used;
• Honor opt-out/unsubscribe requests quickly;
• Allow users to unsubscribe by using the link at the bottom of each email.

Use of cookies and similar technologies

Cookies
We use so-called service cookies primarily to provide the User with services provided electronically and to improve the quality of these services. In connection with this, the Data Controller and other entities providing analytical and statistical services to the Data Controller use cookies, storing information or accessing information already stored in the User’s telecommunications terminal device (computer, telephone, tablet, etc.). Cookies used for this purpose include:

to distinguish unique users by assigning a randomly generated ID. Enables calculation of visitor, session, and campaign data;
to maintain session state for a specific GA4 property. Helps track user interactions across pages within a session.

Google Analytics
We use Google Analytics analytical tools, which collect information about website visits, such as the subpages you have viewed, the time you spent on the website or the time spent switching between individual subpages. For this purpose, Google LLC cookies are used for the Google Analytics service. As part of Google Analytics, demographic data and data on interests are collected. Neither the Data Controller nor Google uses the collected data to identify the User nor does it combine this information to enable your identification. Detailed information on the scope and principles of data collection in connection with this service can be found at the link: https://www.google.com/intl/eng/policies/privacy/partners.

Social networking sites
The Data Controller processes personal data of Users visiting our profiles in social media (Linkedin, Facebook, Instagram, Telegram). This data is processed solely in connection with maintaining the profile, including for the purpose of informing Users about our activity and promoting various types of events, services and products. The legal basis for the processing of personal data by the Data Controller for this purpose is its legitimate interest (Article 6, paragraph 1, letter f of the GDPR) consisting in promoting its own brand.

Categories of personal data processing

The Data Controller processes the following categories of Personal Data belonging to persons contacting the Data Controller or persons with whom the Data Controller contacts:

• identification data (in particular: name and surname, company name, tax number),
• contact details (e-mail, telephone number, username/nickname in messenger or social media),
• information obtained when using our Website, in particular text files,
• other data provided by you voluntarily in any form – necessary for the purpose for which they were provided.

Sources of obtained data

All data is obtained by the Data Controller in the following manner:

• information provided voluntarily and directly by you (e.g. in the any contact form on the Website);
• information obtained when using our Website, in particular text files;
• data of employees or associates of the Controller’s business partners (contractors, subcontractors) – come directly from them or from their employer/entity they represent;
• from publicly available sources, in particular databases and registers

All confidential information is transmitted using Secure Socket Layer (SSL) technology.

Voluntary provision of data

Personal data is provided voluntarily. However, refusing to provide it may result in the inability to use the site’s functionality, including processing an inquiry submitted via a form, receiving a newsletter or other marketing communications.

Lack of consent to the use of cookies or its withdrawal may result in limited functionality of the Website.

Policy Updates

Pay.Partners reserves the right to update this Privacy Policy as necessary to reflect changes in our practices or for other operational, legal, or regulatory reasons.

Any significant updates will be communicated via our Website or direct notification to affected individuals.

This Privacy Policy is effective as of 10/12/2025.