This Privacy Policy (hereinafter, the “Policy”) sets out the procedure for the collection, processing, storage, transfer and protection of personal information and applies to the website https://payplatinum.io (hereinafter, the “Website”) and the PayPlatinum service (hereinafter, the “Service”). The Policy applies to the personal information of visitors to the Website, persons connecting to the Service to accept payments and their representatives, individuals making payments using the Service, and persons contacting us through contact forms and other communication channels. Reading the Policy is mandatory before starting to use the Website and the Service.

1. General Provisions

1.1. The processing of personal information within the Service is organised and carried out by the Operator, being the person ensuring the operation of the Service. The Operator acts on the basis of this Policy and applicable law.

1.2. Personal information is processed on the grounds specified in Section 5. If the User does not agree with the Policy, the User should refrain from using the Website and the Service.

2. Key Definitions

2.1. Personal information means any information relating directly or indirectly to an identified or identifiable individual.

2.2. Processing means any action or set of actions performed with personal information, including collection, recording, storage, rectification, use, transfer, anonymisation, blocking and deletion.

2.3. Operator means the person ensuring the operation of the Service and determining the purposes and scope of the personal information processed.

2.4. Website means the internet resource located at https://payplatinum.io through which access to the Service is provided.

2.5. Service means the PayPlatinum information technology platform, being a set of software and hardware ensuring interaction between settlement participants in the acceptance of payments.

2.6. Partner means a person engaged in the sale of goods, works or services that is connecting (or has connected) to the Service to accept payments in accordance with the Terms of Use.

2.7. Payer means an individual making a payment in favour of a Partner using the Service in accordance with the Public Offer.

2.8. User means a visitor to the Website, a Partner (its representative) or a Payer.

3. Information Processed

3.1. When filling in the feedback form on the Website, the User provides the following data:

– contact details: a Telegram username or an email address;

– project information: a website address and/or a brief description of the project, provided voluntarily by the User.

3.2. When a payment is made using the Service, the following is processed:

– transaction information: transaction identifier, amount, date, time and status of the payment, name of the Partner;

– technical information necessary to ensure payment security and prevent fraud.

3.3. Information about the Payer that may be transmitted to the Operator by payment infrastructure participants is received in masked or anonymised form.

3.4. The Operator does not store the details of the Payer’s payment instruments, including bank card numbers and security codes.

3.5. When the Website is used, technical data are collected automatically, including through the use of cookies. The User may restrict or disable cookies in the browser settings; in this case, certain functions of the Website may be unavailable.

4. Purposes of Processing

4.1. The Operator processes the User’s personal information for the following purposes:

– handling the User’s requests and communicating with the User, sending replies, notifications and requests;

– identifying Partners, entering into and performing agreements with them, and making settlements;

– processing payments, handling refunds, claims and requests from payment infrastructure participants;

– preventing fraudulent transactions and ensuring security;

– complying with applicable law, including in the area of anti-money laundering, counter-terrorist financing and compliance with sanctions restrictions;

– improving the quality and usability of the Service;

– conducting statistical and analytical research based on anonymised data.

4.2. The Operator collects and stores only the information necessary to achieve the above purposes.

5. Legal Grounds for Processing

5.1. Processing is carried out on a lawful and fair basis. The grounds for processing are:

– the User’s consent, expressed when submitting data through the feedback form;

– the need to enter into and perform an agreement to which the User is a party, including the agreement with a Partner and the agreement with a Payer concluded on the terms of the Public Offer;

– the legitimate interests of the Operator, including ensuring the operation of the Website (including the use of cookies), fraud prevention and ensuring security, subject to the rights and freedoms of the User;

– the requirements of applicable law.

6. Processing Conditions

6.1. The Operator ensures the confidentiality of personal information throughout the entire period of its processing.

6.2. The Operator relies on the good faith of the User and does not verify the accuracy of the data provided, except for the verification of Partners upon connection to the Service and cases where such verification is necessary for the performance of obligations or is required by law.

6.3. The User shall independently ensure the confidentiality of its credentials and shall not disclose them to third parties.

6.4. The Website and the Service are not intended for use by persons under the age of 18. The Operator does not knowingly collect personal information of such persons.

7. Disclosure of Information to Third Parties

7.1. The Operator does not disclose personal information to third parties, except in cases provided for by applicable law, including upon requests from competent authorities and banks in the course of checks carried out in accordance with the law.

7.2. Transaction information that the Operator transfers to Partners and payment infrastructure participants for processing payments, refunds and claims does not contain personal information of Payers.

7.3. Data storage and technical maintenance of the Service may be carried out with the involvement of persons providing hosting and technical support services to the Operator. Such persons are obliged to maintain confidentiality and comply with the requirements of this Policy.

8. Place of Processing

8.1. The Operator processes personal information in compliance with the requirements of applicable law regarding the place of storage and processing of personal data, including data localisation requirements where they apply to the relevant processing.

8.2. The Operator ensures the protection of personal information in accordance with this Policy regardless of where it is processed.

9. Rights of the User

9.1. The User has the right to:

– receive information concerning the processing of its personal information;

– request the rectification, blocking or destruction of data if they are incomplete, outdated, inaccurate, unlawfully obtained or not necessary for the stated purpose of processing;

– withdraw consent to the processing of personal information;

– appeal against the actions or omissions of the Operator in the manner provided for by applicable law.

9.2. Upon withdrawal of consent, the Operator ceases processing and deletes the data, unless their storage is required for other lawful purposes.

9.3. To exercise its rights or withdraw consent, the User sends a request to the address specified in clause 11.2. The Operator considers the request within the period established by applicable law.

10. Retention Periods and Security Measures

10.1. Personal information is stored for the period necessary to achieve the purposes of processing, as well as for the period established by applicable law for the retention of documents. Once the purposes of processing have been achieved, the data are destroyed or anonymised, unless otherwise provided by law.

10.2. Information about Partners and their representatives is stored for the term of the agreement with the Partner and for at least five years after its termination.

10.3. The Operator takes the necessary and sufficient legal, organisational and technical measures to protect personal information against unlawful or accidental access, destruction, alteration, blocking, copying, dissemination and other unlawful actions.

11. Amendments to the Policy and Contact Information

11.1. The Operator may amend this Policy. The new version comes into force upon its publication on the Website, unless otherwise provided by the new version. The current version is always available on the Website.

11.2. All suggestions, requests and questions regarding the processing of personal information should be sent to: info@payplatinum.io.

11.3. This Policy remains in force until replaced by a new version.

11.4. The Policy is drawn up in the Russian and English languages. The English text of the Policy is published at: https://payplatinum.io/en/privacy-policy. In the event of discrepancies between the Russian and English versions, the Russian version shall prevail.