1. General Provisions

For the purposes of the General Data Protection Regulation No. 2016/679 adopted by the European Parliament and the Council on 27 April 2016 (the “GDPR”) Paily is a controller of the personal information provided by you on pailycrypto.com and for any application or web services owned or operated by Paily Crypto Wallet UAB. The term “personal information” as used in this policy shall mean any information that enables us to identify you, directly or indirectly, by reference to an identifier such as your name, identification number, location data, online identifier or one or more factors specific to you. By accessing and using our Application, 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. Paily is the controller of your personal data collected through the Application and we are committed to protecting and respecting your privacy. Please take a moment to read this Privacy Policy carefully. If you have any questions about this Privacy Notice, please contact us at support@paily.io

Please note that since you will be providing us the information of your addresses which are also available on blockchain, we would be able to access complete information regarding your assets and VCs. You are free to choose whether to provide us with all the types of personal information requested by us, but we may not be able to serve you as effectively or offer you all of our services on the Application when you do choose not to share certain information with us.

2. Paily Data Privacy Principals

Paily will acquire, use and provide appropriate personal information, giving consideration to the business content and scale, with respect to the personal data collected from you.

Paily will specify the purpose of the use of personal information and take appropriate measures to ensure the use of personal information does not exceed that purpose.

Paily will comply with the laws regarding the use of personal information, policies set by the government and other related regulations.

Paily will promptly respond to requests for disclosure of, inquiries about and complaints regarding personal information, by the establishment of an enquiry desk or to provider of the information.

Paily will review and appropriately improve the information security management system from time to time as per the applicable laws and accepted industry standards.

3. Your Right to Privacy

Applies specifically to Europe: We collect and process personal information about you only in the aforementioned circumstance and where we have a legal requirement to prevent fraud and identify the customers’ transaction on the Site given the nature of the services provided on our Site, to ensure compliance to the applicable laws. The legal bases will depend on the purpose for which we process your personal information. This means we collect and use your personal information only where:

We need it to provide the services, including to operate the Site, provide customer support and personalized features and to protect the safety and security of the Site;

It satisfies a legitimate interest (which is not overridden by your rights and interests), such as for research and development, to market and promote the Site and to protect our legal rights and interests;

You give us consent to do so for a specific purpose;

We need to process your personal information to comply with a legal obligation or requests from governmental or statutory authorities.

4. Rights of the User

In certain circumstances, you have rights under the GDPR in relation to your personal information. These data privacy rights do not apply to Coin Switch where we process your personal information as a data processor on behalf of our clients. Where this is the case, any request to exercise your data privacy rights should be directed to our client (i.e. the data controller).

Request access to your personal information. You may have the right to request access to any personal information we hold about you as well as related information, including the purposes for processing the personal information, the recipients or categories of recipients with whom the personal information has been shared, where possible, the period for which the personal information will be stored, the source of the personal information, and the existence of any automated decision making.

Request correction of your personal information. You may have the right to obtain without undue delay the rectification of any inaccurate personal information we hold about you.

Request erasure of your personal information. You may have the right to request that personal information held about you is deleted.

Request restriction of processing your personal information. You may have the right to prevent or restrict processing of your personal information.

Request transfer of your personal information. You may have the right to request transfer of personal information directly to a third party where this is technically feasible.

4.1. Withdrawal of Consent

Each User has the right to withdraw the consent to processing of personal data in accordance with this Policy.

In order to withdraw the consent, the User shall send an email to the email address of Paily at support@paily.io./p>

If the User withdraws the consent to processing of personal data, Paily is entitled to refuse provision of the Services provision of which is impossible without processing of User’s personal data.

The fact that the User withdraws the consent to personal data processing does not affect the legality of the personal data processing carried out by Paily prior to withdrawal.

Paily may refuse to delete personal data of any User or does not take into account the withdrawal of consent to processing of personal data if there are other legitimate grounds provided by GDPR enabling Paily to continue processing of personal data.

4.2. The User also have the following rights guaranteed by GDPR:

• The right to erasure of personal data subject to the grounds provided for in Art.17 GDPR.
• The right to object to processing of personal data (which includes objection to processing for direct marketing purposes).
• The right not to be subject to a decision based solely on automated processing, including profiling.
• The right to file a request or complaint with Paily as the Controller of personal data.
• The right to lodge a complaint with a supervisory authority in accordance with Art.77 GDPR.
• The right to an effective judicial remedy against Paily or its Processors in accordance with Art.79 GDPR.

To exercise any of the rights provided above, the User shall send a request to the email address of Paily at support@paily.io

Paily is deemed to have received the request of the User on the 7th (seventh) business day after the dispatch of the email, if the shorter term is not provided by GDPR or other applicable personal data legislation.

Paily shall respond to the request sent by the User within 30 (thirty) days, if the shorter term is not provided by GDPR or other applicable personal data legislation.

5. Personal Data Processed

We use different methods to collect personal information from and about you. We can classify the same into two heads – the information provided by you and the information collected by us.

5.1. Personal Information You Give Us

A)You may give us your personal information including:

• full name and contact details
• date of birth
• country of residence
• full address (including ZIP)
• telephone number

by subscribing in forms or by corresponding with us by post, phone, email or otherwise. This also includes the addresses associated with your VCs which you will choose to give us while accessing our Service, Products, Application.

B)You may also provide us with the corporate information about the User, namely:

• the name of the legal entity (if the User is the legal entity);
• the registration information about the User (the registration number of the User as the entrepreneur or legal entity, TIN and VAT numbers, if applicable)
• the payment details of the User (including information about bank accounts or online wallets of the User which is necessary and sufficient for making payments in favor of such accounts).

C) You may also provide us with the information about User’s representative (if the User is a Business User as defined in the Terms and the User Agreement for the Provision of Business Service), namely:

• the first and family name of the User’s representative
• tdate of birth if a representative is an individual
• the information about the status (role) of the representative in respect to the User
• the representative’s country of residence and full address (including ZIP)
• the representative’s email address and telephone number.

5.2. Email Communications

From time to time, we may send out emails for promotion purposes to announce our services, functions, researches, news, promotions, contests and events. Our customers may opt-out of receiving these emails. We may use a third-party service provider to send out emails or to communicate smoothly with our customers. For a smoother communication, we may share information, such as your email address, to the service provider for this limited purpose only. You can opt out by following the unsubscribe instructions included in these emails, or you can contact us by emailing us on support@paily.io.

6. Cookies

Like many websites, we also use ‘Cookies’ to make our Site more convenient to our customers. Cookies are small text files downloaded by the internet browser of the User to his PC/tablet computer, mobile phone or any other device used by the User for access to the Site.

Cookies are used in order to ensure a personalized experience of the Site use and convenient Site navigation. They help to track the most visited web pages, determine the efficiency of advertising and web searches, and give an indication of the User behavior, thereby contributing to improvement of communication means and products offered to User.

Information that Paily gets through the cookies helps to deliver the Services in the most convenient way. By using the Site and providing consent to processing of personal data, the User agrees with the placement of cookies in his device under the terms of this Policy.

The cookies also help the User not to lose data inserted into the request form, when the Site page is refreshed. Please note that Paily does not guarantee a correct work of the Site in the User’s browser, if the User does not provide consent to processing of cookies.

6.1. Term of Storage of Cookies

Some cookies operate from the moment of the User’s access to the Site till the end of a particular session in the browser. These files become useless and they are automatically deleted upon closing the browser. Such files are called session cookies.

Some cookies are also saved on device between the sessions in the browser and they are not deleted after the browser is closed. Such cookies are called persistent cookies.

You can find information on how to turn off cookies or change cookie settings for your browser by clicking on the following links:

• Google Chrome: https://support.google.com/chrome/answer/95647
• Firefox: https://support.mozilla.org/en-US/kb/enable-and-disable-cookies-website-preferences
• Internet Explorer: https://windows.microsoft.com/en-GB/windows-vista/Block-or-allow-cookies
• Safari: https://help.apple.com/safari/mac/8.0/#/sfri11471

TMost browsers allow you to see the cookies stored on your device and individually delete or block cookies from certain or all websites. Please note that when you delete all cookies, all of your preferences will be lost, including the preference for not using cookies, since it implies the setting of a cookie that provides this failure. More information on changing your browser's settings for blocking or filtering cookies is available at http://www.aboutcookies.org/ or http://www.cookiecentral.com/faq/.

7. Personal Data and Third Parties

We share your data with third party service providers and online market platforms like Facebook, Twitter, Mailgun, Mailchimp, etc. for marketing and promotion of our company and to make the advertising more relevant for the end-users. If you do not want Paily to share your data with third parties for the promotion of our company, please contact us by emailing on support@paily.io.

We may also transfer personal data of User to Third parties, if it is required by applicable law, regulation, court proceedings, or request issued by a public authority, or if such information needs to be disclosed for the settlement of conflict situations (in particular, with respect to the Services), ensuring security to the User.

The personal data of User may be provided by Paily to Third parties in connection with such events as merger or sale of Paily’s assets, amalgamation and restructuring, financing, and acquisition of a business as a whole or in part, or during the negotiations of such matters.

Paily may disclose personal data of the User to Third parties in situations which are not expressly stated hereby, subject to obtaining the User’s consent to disclosure of information pertaining to him/her.

We may share User’s personal information with any member of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries.

As well as with selected third parties including business partners, suppliers and sub-contractors for the performance of any contract we enter into with them with analytics that assist us in the improvement and optimisation of the Application.

We may share User’s information with third party service provides for information security and fraud detection and for prevention of illegal activities.

8. Purposes of Using Personal Data

Paily has the right to use personal data of Users for the following purposes:

• Identification of the User or/and User’s representative
• Provision of the Services and the services related to the Services to Users (including processing of payments made by Clients and facilitating withdrawals of funds)
• Communication with Users
• Marketing and advertising purposes
• Analytical purposes
• Resolving disputes with Users or Clients
• Improving the work of the Site and the Applications
• Improving the quality of the Services
• Providing Clients with the opportunity to pay for goods, services, or work of Users
• Processing payments of Clients
• Resolving disputes with Users or Clients
• Improving the work of the Site, Wallet and the Applications
• Improving the quality of the Services
• Analytical purposes
• Marketing and advertising purposes
• Helping Users in application installation and registering as new App users
• Delivering services to Users as part of the use of the Application

Notifying of any changes to the Application or services provided on the Application.

9. Service Providers

Our service providers provide us with a variety of administrative, statistical, and technical services. We will only provide service providers with the minimum amount of personal data they need to fulfil the services we request, and we stipulate that they protect this information and do not use it for any other purpose. We take these relationships seriously and oblige all of our data processors to sign contracts with us that clearly set out their commitment to respecting individual rights, and their commitments to assisting us to help you exercise your rights as a data subject. At present Amazon Web Services (AWS), Google Analytics, Mailchimp, and Firebase are trusted third party service providers of ours.

11. Exercising Your Rights

When you write to us making a request to exercise your rights we are entitled to ask you to prove that you are who you say you are. We may ask you to provide copies of relevant ID documents to help us to verify your identity.

It will help us to process your request if you clearly state which right you wish to exercise and, where relevant, why it is that you are exercising it. The clearer and more specific you can be, the faster and more efficiently we can deal with your request. If you do not provide us with sufficient information then we may delay actioning your request until you have provided us with additional information (and where this is the case we will tell you).

For details on your rights to ask us to stop sending you various kinds of communications, please, email us on support@paily.io

13. Enactment and Updating of the Policy

This version of the Policy shall come into effect on 27 September, 2022 and remain valid until the approval of a new version of the Policy.

Paily reserves the right to make at its own discretion any amendments to this Policy at any time.

If Paily provides this Policy with amendments, Paily will post the updated version of the Policy on the Site. The new version of the Policy shall come into force upon posting of the new version on the Site.

By posting the new version of the Policy on the Site, Paily notifies Users about the enacted amendments of the Policy.

Paily may also send emails to Users notifying the Users about the enacted amendments of the Policy. However, the absence of such emails does not affect the legality and validity of the updated version of the Policy.

By continuing to browse the Site or establish contractual relations with the User after the new version of the Policy is enacted, the User agrees to processing of his personal data in accordance with the updated version of the Policy.

By continuing to use the Services after the new version of the Policy is enacted, the User agrees to processing of his personal data in accordance with the updated version of the Policy.