We respect your privacy and are committed to protecting your privacy rights. Please take the time to read this Privacy Policy carefully. We want to be clear about how we use information, and about how you can protect your privacy. To ensure transparency, this Privacy Policy describes our information-handling practices when you access the Paysenger Platform and our mobile or desktop device-based applications.

If you have any questions, please feel free to contact us at: support@paysenger.com.

References in this Policy to “Paysenger”, “we”, “our” or “us”, are to ATTN CAPITAL EU LTD and references to “you”, “your”, “customer” or “user” are to the person who is a user of the Paysenger Platform. All the definitions used in this Privacy Policy shall have the same meaning as in our General Terms of Service unless this Policy sets a different meaning.

By accessing or registration at the Paysenger Platform, downloading mobile or desktop device-based applications from Paysenger you signify acceptance to the terms of this Privacy Policy. Where we require your consent to process your personal information, we will ask for your consent to the collection, use, and disclosure of your personal information as described further below.

IF YOU DO NOT AGREE WITH THIS POLICY PLEASE LEAVE THE PAYSENGER PLATFORM, UNINSTALL OUR APPLICATIONS AND CEASE USING RELATED SERVICES IMMEDIATELY.

1. We will act as a data controller in relation to personal information about you that may be either provided by you or collected by us.
2. As a data controller, we will solely determine the purposes and means of the processing of your personal information.

1. In this Section 2 we have set out
   1. the general categories of personal information that we may process;
   2. the purposes for which we may process personal information; and
   3. the legal basis of the processing.
2. Please note that not all the information you provide to us is personally identifiable information according to the applicable law. By registering at the Paysenger Platform you will provide and share your personal information with the public and with other users. Information you provided to the public sections of the Paysenger Platform or of your profile can be seen by anyone. This personal information is made available to the public to help you connect and/or transact with other users. Please be advised that public personal information can be shown up when someone does a search on the Paysenger Platform or another search engine. Please be aware that people you share your personal information or communicate with may download or copy the information you provided to them or make it public. Use caution about the personal information you share with others.
3. It is your sole decision whether to provide us with the requested information or not. However, if you choose to withhold requested information, we may not be able to create an Account for you at the Paysenger Platform or provide you with the possibility to use related services. Depending upon the activity, some of the information that we ask you to provide is identified as mandatory and some as optional. Please do not supply any other person’s personal information to us, unless we prompt you to do so.
4. Usage Data. We may process information about your use of the Paysenger Platform (“usage data”). The usage data may include:
   1. your IP address, geographical location, browser type and version, operating system, referral source, length of visit, page views and navigation paths, as well as information about the timing, frequency and pattern of your use;
   2. your device number, device id or unique identifier, device type, and unique device token, operating system and applications used, application crash-data, application version, device identifiers such as IDFA (Identifier For Advertisers), Android ID (Android device), referrer URL (Playstore), Google Advertiser ID, device model;
   3. cookies, local storage files. The source of the usage data is our analytics tracking system and your usage of the Paysenger Platform. This usage data may be processed for the purposes of analysing the use of the Paysenger Platform and to keep you signed in at the Paysenger Platform. The legal basis for this processing is your consent and our legitimate interest, namely monitoring and improving the Paysenger Platform and our services.
5. Account data. We may process your account data (“account data”). The account data may include your name, nickname (or username), phone number, email address, profile photo, social media identifiers, profile information. The source of the account data is you. The account data may be processed for the purposes of providing you access to our services, ensuring the security of the Paysenger Platform, Creator Services and Paysenger Services and communicating with you. The legal basis for this processing is a performance of an agreement between you and us and/or taking steps, at your request, to enter into such an agreement.
6. Interaction data. We may process information that you generate while using the Paysenger Platform, Creator Services or through your participation in communications, chats, calls with other users (“interaction data”). The interaction data may include your photos and videos, interests, favourites, text messages, voice messages and/or any other information you add to your profile or use in communication with other users, sending Requests to Creators and/or delivering, making accessible any content (including Creator Content). The source of this interaction data is you and your activities at or through the Paysenger Platform. This data may be processed for the purposes of providing relevant services to you. The legal basis for this processing is the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract.
7. Customer relationship data. We may process information contained in or relating to any communication that you send to us, or relating to our customer relationships with you (“customer relationship data”). The customer relationship data may include your name, your nickname (or username), your contact details (phone number, social media identifier, email address or messengers identifiers you use to communicate with us) and information contained in communications between us and you. The source of the customer relationship data is you. The customer relationship data may be processed for the purposes of managing our relationships with customers, communicating with customers, customer support, quality assurance of our customer support and communication with customers, keeping records of those communications and promoting our products and services to customers. The legal basis for this processing is a performance of an agreement between you and us and/or taking steps, at your request, to enter into such an agreement and our legitimate interest, namely the proper management of our customer relationships and administration of the Paysenger Platform.
8. Verification data. We may process information when we verify your identity (“verification data”). The verification data may include your name, address, telephone number, e-mail address, date of birth, national identification number, government identification documents, and, if applicable, information regarding your bank account (such as the name of the bank, SWIFT or the bank code, and account number). Also, this verification data may include your driving license or any other national ID, internal or international passport, bank statement, utility bill, tax document and/or other documents that we consider necessary for your identification. We may request from you video identification or your selfie with a specified ID or passport. The source of this data is you. This verification data may be processed for the purposes of identity verification and the detection of money laundering, terrorist financing, fraud, or any other financial crime, and/or performance our obligations to verify the identity of our customers. The legal basis for this processing is the compliance with our legal obligation, the protection and assertion of our legal rights, your legal rights and the legal rights of others, the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract.
9. We may process any of your personal information identified in this Policy where necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure, or for detecting, preventing and addressing fraud and other illegal activity. The legal basis for this processing is our legitimate interest, namely the protection and assertion of our legal rights, your legal rights and the legal rights of others.
10. We may process any of your personal information identified in this Policy where necessary for the purposes of managing risks or obtaining professional advice. The legal basis for this processing is our legitimate interest, namely the proper protection of our business against risks.
11. Sensitive Data. We do not require you to provide us with personal information revealing your racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership or sexual orientation (“sensitive data”). If you decide to provide us, the Paysenger Platform users or any third party with and/or allow your sensitive data to be publicly viewed through your profile, it should be your voluntary decision taken solely by you. We additionally inform you that information that is public can be seen by anyone and people you share and communicate with may download or copy the content or information you provided to them or make it public. Use caution about the personal information you share with others.
12. In addition to the specific purposes for which we may process your personal information set out in this Section 2, we may also process any of your personal information where such processing is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another individual.

1. We may process your personal information identified in this Policy to keep you informed about our new products, product upgrades, special offers, webinars, events and promotions that may be of interest to you, to send you updates regarding services you have shown interest in or provide further information related to the topic you requested, or to get your consent to further contacting you regarding any other services you might be interested in. The legal basis for this processing is our legitimate interest, namely the development and conducting of our business.
2. We may use your personal information to send you promotional emails and/or newsletters when you have consented to receive such communications. The legal basis for this processing is your consent to receive promotional communications from us.
3. We may use aggregate, non-identifying statistical data for statistical analysis, marketing, or similar promotional purposes to help improve our offerings to you or to improve your browsing experience by personalising the Paysenger Platform.

1. As with many other websites in the world, the Paysenger Platform uses cookies. A cookie is a small file on your device with a string of letters and numbers which serves as a unique identifier. Sometimes cookies can also be used to store your personal preferences on websites. When you open the Paysenger Platform for the first time, cookies are created on your device. When you open it next time, cookies are sent back to us, thus letting us know you’ve already been there. We don’t create cookies ourselves, but we use third-party providers who do it for us.
2. Cookies make it easier for you to use the Paysenger Platform during future visits. They also allow us to monitor traffic and personalise the content of the Paysenger Platform for you. Session-based cookies only last while your browser is open, and are automatically deleted when you close the browser. Persistent cookies last until you or your browser deletes them or until they expire.
3. Some of our cookies are necessary for certain uses of the Paysenger Platform. These cookies allow us to make the Paysenger Platform usable by enabling basic functions like page navigation. The Paysenger Platform may not function properly without these cookies.
4. We may also use functional cookies and cookies from third parties for analysis and marketing purposes. Functional cookies enable certain parts of the Paysenger Platform to work properly and your user preferences to remain known. Analytics cookies, among other things, collect information on how visitors use the Paysenger Platform, the content and products that users view most frequently, and the effectiveness of our third-party advertising.
5. We generally use cookies for the following purposes:
   1. authentication – we use cookies to identify you when you visit the Paysenger Platform and as you navigate through the Paysenger Platform;
   2. status – we use cookies to help us to determine if you are logged into the Paysenger Platform;
   3. security – we use cookies as an element of the security measures used to protect user Accounts, including preventing fraudulent use of login credentials, and to protect the Paysenger Platform and our services generally;
   4. analysis – we use cookies to help us to analyse the use and performance of the Paysenger Platform and services; and
   5. cookie consent – we use cookies to store your preferences in relation to the use of cookies more generally.
6. We use analytics packages from trusted third parties to constantly improve your experience of using the Paysenger Platform and related services. Our trusted partners help us serve advertising and/or analytics and may place cookies on your device. You can find their privacy policies in the list below. Please read their privacy policies to ensure that you are comfortable with the manner in which they use cookies.
7. We use the following third-party services to monitor and analyse web traffic and user behaviour:
   1. Google Analytics. Google Analytics is a web analysis service provided by Google Inc. Google utilises the data collected to track and examine user behaviour, prepare reports, and share insights with other Google services. Google may use the data collected to contextualize and personalize the advertisements launched via Google’s advertising network. The service is subject to Google’s Privacy Policy: https://policies.google.com/privacy?hl=en
   2. Stripe. Stripe, Inc. is a payment services provider. Stripe utilises the data collected to detect and prevent fraud. The service is subject to Stripe’s Privacy Policy and Cookies Policy. Stripe’s Privacy Policy is available via the link: https://stripe.com/en-nl/privacy Stripe’s Cookies Policy is available via the link: https://stripe.com/cookies-policy/legal
   we do our best to keep this list updated, please note that third parties who place cookies on your device may change from time to time, and there may be a slight delay updating the list.
8. can generally activate or later deactivate the use of cookies through a functionality built into your web browser or mobile device. To learn more about how to control cookie settings through your browser:

   Firefox link

   Chrome link

   Internet Explorer link

   Safari (Desktop) link

   Safari (Mobile) link

   Android Browser link

   You can opt out of interest-based targeting provided by participating ad servers through the Digital Advertising Alliance. Please consult http://www.aboutads.info/ for more information.

1. We may use local storage files to keep you signed in at the Paysenger Platform if you choose so. You can delete local storage files from your device at any time by visiting your device’s settings.
2. Local storage, including Javascript-enabled localStorage, is a typical way for a website to store a small file of letters and numbers in your browser. We use local storage files to keep you signed in at the Paysenger Platform and to keep your account authorisation settings. Local storage files are deleted when the website that stored them deletes them. You can also delete local storage files from your browser at any time you like by visiting your web browser settings.
3. You can clear local storage files from your browser by taking the following actions:
   1. In Firefox, localStorage is cleared when the following conditions are met: (a) user clears recent history, (b) cookies are selected to be cleared, and (c) time range is “Everything”;
   2. In Chrome, localStorage is cleared when the following conditions are met: (a) clear browsing data, (b) "cookies and other site data" is selected, and (c) timeframe is “from beginning of time.” In Chrome, it is also now possible to delete localStorage for one specific site;
   3. In Internet Explorer, to clear localStorage: (a) click on Tools--Internet Options, (b) General tab, (c) delete browsing history on exit, (d) ensure “Cookies and website data” (or “temporary internet files and website files”) is selected, and (e) consider unchecking "Preserve Favorites website data" at the top;
   4. In Safari, to clear localStorage: (a) click Safari, (b) then click preferences, (c) select the Privacy tab, (d) click Remove all website data and (e) click Remove Now.

1. Our processing means any operation or set of operations which is performed on personal information, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction, support, maintenance, etc. We do not make automated decisions, including profiling. The processing of personal information is carried out using computers and/or IT enabled tools, following organisational procedures and modes strictly related to the purposes indicated.
2. Your personal information is processed at our operating offices and in any other place where the parties involved with the processing are located.
3. Your personal information is stored on cloud services provided by Amazon. Amazon Privacy Notice is available at https://aws.amazon.com/privacy.
4. We have implemented measures designed to secure your personal information from accidental loss and unauthorised access, use, alteration, and disclosure.

1. We may disclose your personal information to our affiliates, our contractors and our service providers insofar as reasonably necessary for the purposes, and on the legal bases, set out in this Policy. For example, we may share your personal information with our service providers who perform identity verification of users, however, in some cases you may directly interact with such service providers and they will act as data controllers in relation to the personal information you provide to them directly.
2. Your personal information may be accessible to certain types of our employees or contractors, involved with the operation of the Paysenger Platform (customer support, marketing, moderation, compliance, legal, system administration) or external parties (such as third party technical service providers, identity verification service providers, hosting providers, software development service providers, communication agencies) appointed, if necessary, as data processors by us.
3. We also have relationships with partners or vendors that provide features and services directly to you when you use the Paysenger Platform. For example, when processing a payment to you or to charge your payment method, or when require you to verify your identity directly with our identity verification partners. In these cases, such a partner is not acting as a service provider to us and is transacting with you directly. The data passed to them is the information necessary to facilitate the type of service they provide directly to you.
4. In addition to the specific disclosures of personal information set out in this Section 7, we may disclose your personal information where such disclosure is necessary (i) for compliance with a legal obligation to which we are subject or in response to a subpoena, court order, or other legal mechanisms, or (ii) in order to protect your vital interests or the vital interests of another natural person. We may disclose your personal information to our professional advisers insofar as reasonably necessary for the purposes of managing risks, obtaining professional advice, or the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure or detecting, preventing and addressing fraud and other illegal activity.
5. If we transfer your personal information outside the EEA zone, UK or Switzerland, we will ensure an adequate level of protection by any of the recognised methods of transfer, including but not limited to entry into the standard contractual clauses for the transfer of personal information to processors established in third countries.

1. We only retain your personal information for as long as it is necessary for us to use your information as described above or to comply with our legal obligations and legitimate interests. For instance, we may retain your information as necessary to meet our legal obligations, such as for tax and accounting purposes.
2. We will retain your personal information no longer than 5 years from: i) your last sign in to the Paysenger Platform, ii) the last delivery of our services to you, or iii) our last interaction with you related to your inquiry about the Paysenger Platform, our services or any other issues you have related to the Paysenger Platform or related services, whichever is later.
3. We will store your personal information that is used to send you promotional e-mails and/or newsletters or used in relation to your support tickets. Such information will be stored and processed solely for this purpose until you withdraw your consent, where applicable, or unsubscribe from newsletters, but not longer than for 5 years after your last interaction with us.
4. Otherwise, we either delete or anonymise the personal information collected. In case personal information was transferred to backup storage and, therefore, cannot be deleted, we continue to store it securely, but do not use it for any purpose. In all the other cases, we proceed with the deletion of personal information.
5. Account Deactivation. At any time, you can deactivate/cancel your Account and erase your personal information by emailing support@paysenger.com. If you choose to deactivate your Account, we will generally delete all your personal information and it will not be recoverable should you later create another Account.

1. The Paysenger Platform may contain links to any other websites or services. Please note that we are not responsible for the privacy practices or the content of such websites or services, and you should review the privacy policy of each such website or service to make sure you are comfortable with it before providing any personal information.

As a data subject (a person whose personal information is collected, stored and processed) you have several rights under data privacy laws:

1. Right of access. You have the right to obtain confirmation if your personal information is being processed by us. If that is the case, you can access your personal information and the following information: (i) the purposes of the processing; (ii) the categories of personal information; (iii) to whom the personal information has been or will be disclosed; (iv) the envisaged period for which the personal information will be stored, or the criteria used to determine that period.

   If you would like to have a copy of your personal information from us, we will provide it if (i) you prove your identity, (ii) it will not adversely affect the rights and freedoms of others. The first copy will be provided for free, for any further copies we may charge a reasonable fee based on administrative costs.

2. Right to rectification. You have the right to demand that we correct without undue delay your personal information which we have in our systems if it is inaccurate or incomplete.
3. Right to erasure (“right to be forgotten”). You have the right to demand that we erase your personal information, and we shall erase it without undue delay where one of the following grounds applies: (i) this personal information is no longer necessary in relation to the purposes for which it was processed; (ii) you withdraw consent on which the processing is based, and where there is no other legal ground for the processing; (iii) you object to the processing and there are no overriding legitimate grounds; (iv) your personal information has been unlawfully processed; (v) your personal information has to be erased for compliance with a legal obligation.
4. Right to restrict processing. You have the right to restrict us in the ability of processing your information where one of the following applies: (i) you contest the accuracy of your personal information and we are verifying it; (ii) the processing is unlawful and you want to restrict it instead of erasure; (iii) we no longer need your personal information, but you need it for establishment, exercise or defense of legal claims; (iv) you have objected to processing and we are verifying whether legitimate grounds override your request.

5. Right to data portability. You have the right to receive your personal information which you provided to us in a structured, commonly used and machine-readable format and have the right to transmit those data to another company, where: (i) the processing is based on your consent or on a contract; and (ii) the processing is carried out by automated means.

   Where technically feasible, you can demand that we transmit those data directly to another company.

6. Right to object. You have the right to object to the processing of your personal information based on our legitimate interests. We shall no longer process your personal information unless we demonstrate compelling legitimate grounds for the processing or for the establishment, exercise or defense of legal claims.

   Where personal information is processed for direct marketing purposes, you have the right to object at any time to the processing of your personal information for such marketing.

7. Right to withdraw consent. You have the right to withdraw your consent for processing of your personal information at any time. The withdrawal of consent shall not affect the lawfulness of processing based on consent before its withdrawal.

1. We may modify this Privacy Policy by providing notice of such changes, such as by sending you an email, providing notice through the Paysenger Platform or updating the “Last Updated” date at the bottom of this Privacy Policy. By continuing to access or use of the Paysenger Platform, you confirm your agreement to the modified Privacy Policy. If you do not agree to any modification to this Privacy Policy, you must stop using the Paysenger Platform and related services, and delete our applications from your devices. We encourage you to frequently review the Privacy Policy to ensure you understand the terms and conditions that apply to your access to, and use of, the Paysenger Platform and related services.

1. If you have any requests concerning your personal information or any queries with regard to this Privacy Policy please feel free to contact us at support@paysenger.com or our mailing address below:

   ATTN CAPITAL EU LTD

   John Kennedy, 8, IRIS HOUSE, Floor 7, Office 740C 3106, Limassol, Cyprus

Last Updated on 25 November 2021