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Privacy Policy February 12, 2020

OVERVIEW

In order to operate the Coinexo Services and to prevent fraud and reduce its risk, PayRCurrency OÜ, a company incorporated under the laws of Estonia, under register code 14860404, having its registered office at Harju maakond, Kristiine linnaosa, Laki tn 14a, 10621, Tallinn, Estonia, acting as the data controller, is obliged to ask you to provide us with information about yourself, including your business bank account details or eWallet addresses, and corporate details and sensitive data. By consenting to, and agreeing the terms of, this Privacy Policy, you agree to us processing your data in the manner set below. This Privacy Policy describes the collection and usage of information about you. coinexo.io (PayRCurrency OU) takes the processing of your information very seriously and will use your information only accordingly to the terms described in this Policy. For the purposes of this Privacy Policy, the term “information” and Personal Data means any confidential and/or personally identifiable information or other information related to users of Coinexo and/or related Services provided by PayRCurrency OU and through its subsidiaries, including but not limited to customers and merchants (legal entities). Your information will not be sold or rented to any third parties for their marketing purposes without your explicit consent. However, in order for us to offer Coinexo and/or related Services provided by PayRCurrency OU and through its subsidiaries, to our users; enhance the quality of Services from time to time; and protect the interests of our users, we will in limited circumstances share some of your information with third parties under strict restrictions. It is important for you to review this Privacy Policy as it applies to all the PayRCurrency Services. This Privacy Policy is intended to govern the use of Coinexo and/or related Services provided by PayRCurrency OU and through its subsidiaries, by our users (including, without limitation those who use the Coinexo Services in the course of their trade or business) unless otherwise agreed through contract.
PayRCurrency OU appointed Data Protection Officer, for any questions regarding this Privacy Policy please contact: compliance@Coinexo.io
Changes to this Privacy Policy:
All future changes to this Privacy Policy set out in the Policy Update already published on the Coinexo or PayRCurrency website at the time you register for the Coinexo Services. All the changes will take effect as specified in the Policy Update. “Policy Update” means a prior notice of changes to any of your agreements with Coinexo which PayRCurrency OU may make available to you in writing. If you disagree with the terms of this Privacy Policy, please do not register for or use the Coinexo Services.

Notification of Changes:

This Policy may be revised and updated as new features are added to the Coinexo Services or as we incorporate suggestions from our customers. We may change this Privacy Policy at any time by posting a revised version of it on our website. Unless we have legal grounds to do otherwise, we will provide you with at least 30 days’ prior notice of the effective date of the revised privacy policy. We may notify you about the changes in the Policy by posting the notice on the ‘Policy page’ of our website(s) and/or notify you by e-mail. In case you disagree with the terms of this Privacy Policy, you may close your account or request closing your account at any time. Please check the Coinexo or any PayRCurrency websites on a regular basis for the most current version of our Privacy Policy. Third Party Websites: Some pages on the Coinexo website include links to third-party websites or our other products. These sites are governed by their own privacy statements (unless the product or link to the
web site belongs to PayRCurrency OU), and PayRCurrency OU is not responsible for their operations, including but not limited to their information practices. Customers who submit information to or 1 through these third-party websites should review the privacy statements of these sites before providing them with personally identifiable information. Not a Framework Contract: For the avoidance of doubt, this Privacy Policy does not constitute a ‘framework contract’ for the purpose of the EU Payment Services Directive (2007/64/EC) or any implementation of that directive in the European Union or EEA (including, without limitation, the UK Payment Services Regulations 2009).

A Special Note about Children: Children are not eligible to use Coinexo or other related PayRCurrency Services and we ask that minors (persons under the age of 18) do not submit any personal information to us or use the Coinexo or PayRCurrency Services.

GENERAL PRINCIPLES

In accordance with this Privacy Policy, we comply with the following principles:

  • Processing activities must be lawful, fair and transparent.
  • Personal Data must be collected for specified, explicit, and legitimate purposes.
  • Personal Data may not be further processed in any way incompatible with those purposes. Processing operations for archiving, public interest, scientific and historical research, and statistical purposes shall be consistent with the original purpose.
  • Personal Data must be adequate and relevant and limited to the minimum necessary for the purposes for which they are processed. 
  • Personal data must be accurate and, where necessary, up to date.
  • Personal Data should be kept in a form which permits identification of data subjects for no longer than is necessary for the purposes for which the data were processed. Personal Data may be kept longer for archiving purposes in the public interest and for historical, statistical or  cientific purposes.
  • Personal Data may only be processed in a way that ensures the security of Personal Data.

PERSONAL INFORMATION WE COLLECT

Providing information to us is voluntary, but any refusal to provide such information may disable us to comply with legal obligations, enter into contract with you, respond to your requests, provide you with our Services, receive and process your request.
We collect information about you when you visit our Sites or use our Services, including the following:
  • Registration and use information – When you register to use our Services by creating an Account, we will collect Personal Data as vital to offer and fulfill the Services you request. The information we require may vary, depending on the service you use: your name, postal address, telephone number, IBAN, personal identification number, email address and identification information to establish an Account. Due to the legal obligations prescribed by relevant laws, we may require you to provide us with additional data: Corporate details and incorporation  documents, information about shareholders and Ultimate Beneficial Owners, transaction history, detailed description of your business, nature of funds etc.
  • Transaction and usage information – When using our Services or Services available through PayRCurrency web site or its subsidiaries, for  example, to make purchases from merchants, to receive money, to process payments, we collect information about the transaction, as well as
    other information associated with the transaction such as amount sent or requested, amount paid for products or services, merchant information, including information about any funding instruments used to complete the transaction, Device Information, Technical Usage Data, and 2 Geolocation Information. We strictly follow AML and CFT Policies and the information about transactions is necessary for providing our Services
    • Send or request funds: When you send or request funds (crypto currencies or fiat) through the Services, we collect Personal Data: name, postal address, telephone number, and financial account information about the participant who is receiving money from you or sending money to you. The extent of Personal Data required about a participant may vary depending on the Services you are using.
    • Pay or request someone else to pay a bill: If you use Services provided by PayRCurrency OU or through its subsidiaries to pay a bill for the benefit of someone else, or if you request a User to pay a bill for you, we collect Personal Data from you about the account holder such as name, postal address, telephone number, email address, and account number of the bill that you intend to pay or request to be paid.
  • Information about your friends and contacts – This is subject for future implementation. In case Coinexo or any product of PayRCurrency OU or its subsidiaries implement a Contact feature in its products, it may be easier for us to help you transact with your friends and contacts if you provide Personal Data such as name, email address and telephone number about your friends and contacts while using a Service or if you connect your contact list or friend list to your Account. If you choose to connect your contact list information on your device with your Account and/or establish an account connection between a social media platform and your Account, we will collect and use your contact list or friend list information to improve your experience when you use the Services.
  • Information that you choose to provide us to obtain additional Services or specific onlineServices – When you request enhanced Services or other elective functionality, we may collect additional information from you. We will provide you with a separate notice at the time of collection, if the use of that information differs from the uses disclosed in this Privacy Policy.
  • Information about you if you transact as a guest – Certain limited Services are available without being required to log in to or establish an Account, also referred to as Guest Transactions. We will collect Personal Data, information about any funding instrument used to complete a Guest Transaction, Device Information, Technical Usage Data, and Geolocation Information as necessary to provide the requested Guest Transactions. If you are an Account holder and choose to make a Guest Transaction, we will collect information about the transaction and may associate it with your Account. If you are not an Account holder and choose to make a Guest Transaction, we will collect and store all information you provide and use and share such information in accordance with this Privacy Policy.
  • Information about you from third-party sources – We obtain information from third-party sources such as merchants, data providers, and credit bureaus, where permitted by law.
  • Other information we collect related to your use of our Sites or Services – Based on our legitimate interests to enhance our Services, we may collect additional information from or about you when you communicate with us, contact our customer support teams or respond to a survey. If you choose not to provide such information, you will prevent PayRCurrency OU from carrying out analytics or communicating with you in certain situations. We can still contact you for administrative purposes with respect to providing our Services.
In case we process Personal Data outside of the listed scope we will ask for your consent. You may, in any case, withdraw your consent and in that case PayRCurrency OU will no longer process your Personal Data for this purpose, without any negative consequences.