We appreciate your choice of our Platform and services.

For the use of the MFPAY LIMITED Platform, the website https://pay.mfpay.me, and the services on them (hereinafter collectively referred to as the "Platform"), and for their further improvement, the Platform ("MFPAY LIMITED", "we", "us" or "our") collects information from you. This Privacy Policy explains how the Platform collects, stores, uses, transmits, and discloses your information.

From time to time, MFPAY LIMITED may review this Privacy Policy. We will notify you by posting the revised Privacy Policy on our Platform and by changing the date “Last Reviewed and Effective” at the top of this Privacy Policy; we may also notify you by other means, such as using the contact information you provided or by a pop-up notice on our Platform. Any changes to this Privacy Policy take effect immediately upon the publication of the updated Privacy Policy, unless otherwise specified or required by applicable law (for example, another form of notification and your consent to consent or refusal, etc.). By continuing to use our Platform, you agree to the revised Privacy Policy to the maximum extent permitted by applicable law.

You should read the Policy in full, but here are a few key points: When you use our Platform, even just browsing it, we receive certain information from you, such as the type of device you are using and your IP address. You may share additional information with us, such as your email address, by creating a personal account or performing other actions available on the Platform. If you have any questions about this Policy, how we collect or process your personal data, or anything else related to our privacy practices, we would like to hear from you, please write to us at hello@mfpay.me.

1. Scope and Concepts of the Privacy Policy
1.1. This Privacy Policy applies to all aspects of our Platform, as well as information we may collect offline.
1.2. This Platform may reference or include websites or content hosted and serviced by other parties over whom we have no control, such as third-party websites, online resources, platforms, social networks, or systems, each governed by its privacy policy and business practices. You understand and agree that MFPAY LIMITED is not responsible for the security, privacy, or business practices of third parties.
1.3. Terms used in the text.
Personal data – any information related to an identified physical person, such as name, identification number, location data, an online identifier, or one or more factors specific to the physical, economic, cultural, or social identity of you as an individual.

2. Information We Collect
2.1. We collect information from you directly, automatically when you visit the Platform, and sometimes from third parties. Some of this information may be considered "personal information" under various applicable laws.
2.2. We consider information that identifies you as a specific identified person as personal information (e.g., your name, phone number, and email address), as well as additional information, including IP addresses and cookie identifiers, if required by applicable law. And if we combine information we consider non-personal with personal information, we will treat the combined information as personal information in accordance with this Privacy Policy. Note that we may de-identify personal information so it is no longer personal, for example, by aggregating it or coding it, sometimes using a function known as "hashing". De-identified information will be treated as de-identified to the maximum extent permitted by applicable law.
2.3. We may collect the following information:

Individual clients:
Email address
Mobile phone number
Full legal name (including previous name and names in the local language)
Nationality
Passport number or any government-issued identification number
Date of birth ("DOB")
Identification (e.g., passport, driver's license, or state-issued ID card)
Residence address
Proof of residence
Additional personal data or documentation at the discretion of our compliance team.

Corporate clients:
Legal name of the company (including official name in the local language)
Incorporation/registration information
Full legal name of all beneficial owners, directors, and legal representatives
Address (principal place of business and/or another physical location)
Proof of legal existence
Business description
Ownership percentage for individual/corporate owners
Contact information for owners, directors, and executive management (if applicable)
Identification (e.g., passport, driver's license, or state-issued ID card) of significant individual beneficial owner of the client organization
Personal data of the significant beneficial owner of each client organization (details about what Personal Data we collect about individuals are listed under "Individual Client" above).
Source of wealth
Expected quantity of bitcoins or other digital assets to be used
2.4. Legal basis for collecting Personal Data.
Performance of a contract, when we provide you with products or services or inform you about them. This includes using your personal information to accept and process orders and process payments.
Legal obligation, to comply with our legal obligations under applicable laws and regulations, as well as anti-money laundering laws and regulations.
Your consent, when we ask for your consent to process your personal information for a specific purpose that we communicate to you. When you give consent to process your personal information for a certain purpose, you may withdraw your consent at any time, and we will cease processing your personal information for that purpose. Withdrawal of consent does not affect the legality of processing based on consent before its withdrawal.

3. Information You Provide
MFPAY LIMITED may collect personal information from you when you:

Create an account, log onto the Platform, or interact with it.
MFPAY LIMITED collects your name and email address, as well as other information you provide, such as your phone number, when you register or log in, update or add information to your account. We require you to create a username and password if you create an account, although we may include other methods, such as through your Apple ID and WalletConnect.
MFPAY LIMITED also collects certain information related to any social network platform account or Apple ID you use to log into your MFPAY LIMITED account or link to it (e.g., your username, bio, and follower count), despite any such account being linked to your MFPAY LIMITED account, logging into MFPAY LIMITED through such an account is entirely up to you.

Providing information about Users and their goods/services/works on the Platform.
We collect information when you send us content, such as video, description, photo, email, text, or other messages (each referred to as a "Submission"). All information posted on the Platform is governed by the Terms of Service. As a result, others may access, use, and share it in accordance with the Terms of Service.
Platform collects information. When you use our Platform, depending on your Role, we collect, in addition to the information provided when creating your account, your name, email address, phone number, and usernames in social networks that you provide, video, and other information uploaded by you.
For the operation of smart contracts, the Platform collects the information necessary to provide you with access to all the Platform's features. However, the Platform does not have access to your wallet or any transactions with it.
We and our third-party business partners may collect information about your visits and actions on our Platform or websites and services. We may combine this information with other personal information that we have received from you or about you. We may share certain information with third-party business partners for similar purposes.

4. Cookies and tracking technologies
When you visit our Platform or otherwise interact with us or our content, we, third-party advertising, and analytical companies and other third-party business partners may use various tracking technologies and other technologies that automatically or passively collect certain information ("Usage Information"). We may use these technologies for a number of reasons, including saving your preferences for future visits to our Platform, maintaining your authorization between visits, providing you with targeted advertising, and providing you with enhanced services. The information we collect may include (but is not limited to):
The date and time of your visit to our Platform;
The sections that you visit on our Platform;
The links that you click on our Platform;
The websites or advertisements that you visit before or after visiting our Platform;
The terms you entered into a search system that led you to our Platform;
IP address, mobile device identifier, or other unique identifier and device usage information used to access our Platform;
Accurate location data from your device if you have consent
Methods that can be used to collect Usage Information include the following:
Cookies are data files placed on a device when it is used to visit the Platform or access our content. Cookies, flash cookies, and other local storage devices can be used for various purposes, such as identifying your device on subsequent visits to our Platform, recalling your authentication information, storing information related to your navigation on our Platform, or enabling certain features. Some cookies are essential for the functioning of the Platform, and without them, some features and services you have requested cannot be provided. If you disable cookies, adjust your device's privacy settings, restrict local storage, or otherwise limit these technologies, you may not be able to use some of our Platform's functions.
Web Beacons. Small graphic images or other web programming code called web beacons (also known as "pixels", "1x1 GIFs", or "clear GIFs") may be included in our web pages and email messages. Web beacons may be invisible to you. Web beacons or similar technologies can be used for several purposes, including counting visitors to the Platform, tracking how users move around the Platform, counting how many emails we sent were opened, and counting whether a link in the email was clicked.
Embedded Scripts. An embedded script is programming code designed to collect information about your interactions with the Platform, such as the links you click on. The code is temporarily downloaded onto your device from our server or a third-party service provider, is active only while you are connected to the Platform, and is deactivated or deleted afterward.
Other Technologies. We may also use other technologies that collect similar information for security and fraud detection purposes.

5. How We Use Information
We may combine the information we receive from you with information from other sources to manage, tailor content, personalize, customize, and improve our Platform. We use your information to:
Fulfill your request on the Platform, or another application, or contract settings and ensure the security of operations (such as verification, messaging, etc.) on the Platform, as well as email delivery and processing information you provide through our Platform;
Service your account, facilitate the use of the Platform, and communicate with you about your account, our relationship with you, and your use of the Platform, for example, by verifying your information, requesting your feedback on a survey, or checking the status of a request. We may send you text messages if you have provided us with your mobile phone number for this purpose;
Establish and manage relationships with you, depending on your Role on the Platform;
Send you promotional emails or text messages from MFPAY LIMITED (not from any third party), if you have agreed to receive them. To stop receiving emails, click the "unsubscribe" link in the footer of the promotional letter; note that even if you unsubscribe, we may still send you messages related to your account or use of the Platform, such as administrative and service announcements;
Provide you and other individuals with service requests, assistance in problem-solving, as well as evaluating and improving our customer service and processes;
Use any provided information, as specified in the applicable Service Terms, which may include public display of some information, such as your name, username, or place of residence;
Communicate with you on administrative matters, such as the applicable Service Terms, or other issues;
Better understand your personal preferences and allow us to offer you improved and personalized messages, services, and offers, both from us and those posted on the Platform by Sellers;
Collect aggregate data about Platform traffic and interactions;
Tailor content and advertising that we show you or others on our Platform or elsewhere, as well as analyze trends and statistics;
Create advertising models using double modeling or other research methodologies;
For internal business purposes, such as improving our Platform, products, and services, as well as compliance with legal requirements and our business practices, such as our record-keeping policies, backup, and document storage;
And for other reasons which (a) we disclose when we ask you to provide your information, (b) with your consent, or (c) as described in this Privacy Policy.

6. How We Share Information
We transmit non-personal information, such as aggregated statistical data and de-identified information, to third parties to the extent permitted by applicable law. MFPAY LIMITED also transmits personal information as described in further detail below. We do not transmit personal information to any third party for use in their proprietary marketing or advertising purposes without your consent.

We may transfer your Personal Data to third parties:
If we believe that sharing is necessary to ensure compliance with the Terms of Service;
To comply with government requirements, including regulatory bodies, law enforcement agencies, and/or judicial authorities;
To third parties providing services to MFPAY LIMITED (e.g., administrative or technical services);
In connection with the sale or transfer of our business or any part of it. In addition, we regularly implement the latest international standards to prevent money laundering, terrorist financing, and circumvention of trade and economic sanctions, which will likely require us to perform a comprehensive check on our clients. This may include the use of third-party data and service providers which we will match with your personal information.

Third Parties Providing Services on Our Behalf
We engage third parties to render certain services on our behalf, such as hosting the Platform or performing Platform functions, providing analytics on Platform usage, order fulfillment, email or other communication dispatch, marketing assistance, analysis or improvement, conducting promotional activities, or other administrative services. We may share information about you with these third parties so that they can perform, provide, or enhance the services they offer to you and to MFPAY LIMITED.

When You Request Us to Transfer Your Information
We may transfer information when you ask us to do so, for example, if you agree to receive a message from a third party, another Platform User, or if you interact with a third-party application.

Administrative Reasons, for Compliance, and Protection of Legal Rights
To the extent permitted by applicable law, we will disclose your personal information according to the law, regulation, court order, or other legal request or process, for example, disclosing information to law enforcement or other government officials or institutions in connection with any investigation, such as fraud, intellectual property infringement, or any other activity that is or may be illegal or may expose MFPAY LIMITED, you, or others to legal liability. This disclosure may include legal requests when we reasonably believe that a response is required by law in a specific jurisdiction, affects users in that jurisdiction, and is in compliance with international standards.
We will disclose your personal information when necessary to initiate, enforce, establish, or protect our legal rights. For instance, we might review information in your account to investigate allegations of hacking or breaches of the applicable Terms of Service. If it is necessary to protect our interests or on official requests by authorized entities, we will disclose your personal information to our legal and other advisors, consultants, law enforcement agencies, or other government bodies.

Protection of Others
We will disclose your personal information to third parties when we believe that disclosure is necessary to protect the rights, property, or safety of another person. For instance, we disclose personal information related to a Platform account if we reasonably believe that the account on the Platform is being used in a way that harms others or violates the applicable Terms of Service.

Business Transfer
In evaluating or engaging in the sale of assets, merger, acquisition, reorganization, bankruptcy, or other transactions, we reserve the right to disclose, transfer, or assign your personal information and communications. By providing your personal information, you agree that we may transfer such information to the acquiring organization without your further consent.

7. Age Restrictions and User Verification
Our Platform is intended for a broad audience and cannot be used by individuals under the age of 18. For this reason, when creating an account on the Platform, we ask you to undergo verification by providing official documents that confirm your age and identity. Furthermore, to maintain a full set of services, access to its features on the Platform is limited for U.S. citizens.

8. Access to Personal Information and Retention Period
Please note that if you decide not to provide us with certain personal information, we may not always be able to provide you with the appropriate product or service of MFPAY LIMITED that you request. For instance, without providing an email address, you will not be able to create an account on the Platform.
If you have an account on the Platform, you can access, view, correct, or update certain personal information collected about you, as well as deactivate or delete the account. If you have any concerns about how we use your personal information, or if you want to access, correct, or delete the personal information that you have provided us, please contact us; see the Contact Us section.

Retention Period
When you request the deletion of your personal information, we will take commercially reasonable steps to delete it from our active databases, but will retain the original information in accordance with our business practices to the extent that it serves the purposes of the Platform's operation (for example, for dispute resolution, compliance with agreements, compliance with legal requirements, record-keeping, backup, and document storage).

9. Data Security
MFPAY LIMITED implements commercially reasonable security measures to protect the information provided to us. We design our systems with your security and privacy in mind. We have appropriate security measures to prevent accidental loss, use or unauthorized access to your information, alteration, or disclosure. We strive to secure your personal information during transmission and storage by using encryption protocols and software. We maintain physical, electronic, and procedural safeguards in connection with the collection, storage, and disclosure of your personal information. In addition, we limit access to your personal information to those employees, agents, contractors, and other third parties who have a business need for such access.

However, no method of transmission over the Internet or method of electronic storage is 100% secure, and you use our Platform and submit information to us at your own risk.
Moreover, our security procedures mean we may request proof of your identity to protect you from unauthorized access to your account password. We recommend using a unique password for your account on the Platform that is not used for other online accounts and logging off when finished using a shared computer.

10. Compliance with GDPR Requirements
MFPAY LIMITED is the data controller for the purposes of the General Data Protection Regulation (EU) 2016/679 ("GDPR"); and "personal information" as used in this Privacy Policy is "personal data" as defined in Article 4(1) of the GDPR. In

some cases, the Platform also acts as a data controller.
This applies to Platform Users from the EU and UK. If you have any questions about how we use your personal data, or about implementing your data protection rights, please contact us at hello@mfpay.me.

The scope of this notice extends to the use of your personal information both through the Platform and otherwise. We process your information for the purposes set out below.

Legal Basis for Information Processing
The Platform processes your information on legitimate grounds.

Provision of Services
We process your information to operate our Platform, provide or support our products and services, or for any other reason you request or allow. This includes, for example, using your information to:
Manage your account on the Platform;
Organize your participation on the Platform as a Platform User or prospective Platform User;
Support the functionality of the Platform;
Organize the operation of the Platform's smart contracts;
Maintain the operation of our Platform in accordance with this Privacy Policy and the applicable Terms of Service;
Provide customer service;

Consent
We process your information based on your consent, where consent is the lawful ground for such processing. This processing includes MFPAY LIMITED providing you with:
Information newsletters, direct emails, and surveys about our Platform; as well as certain other marketing functions. If MFPAY LIMITED relies on your consent as the lawful basis for processing your personal information, you have the right to withdraw your consent for further use of your personal information at any time.

Legitimate Interest
For processing your information when the Platform has a legitimate interest in doing so. This includes, for example, processing your information to:
Provide you with the customer service or technical support you have requested;
Debug and improve current and to create new processes of the Platform;
Provide you with specific information, personalize your experience using the Platform with us, and communicate with you in accordance with your applicable marketing preferences;
Track activities on the Platform to prevent or detect any fraudulent use of the Platform;
Prevent or detect any fraudulent schemes;
As well as to establish, exercise or defend against legal claims or in connection with any court or jurisdiction.

Your Rights to Your Information
You have a number of rights with respect to your privacy and the protection of your personal information. You have the right to request access, correction, and deletion of your personal information, as well as data portability. You may also object to our processing of your personal information or ask us to restrict processing of your personal information in certain instances. Moreover, when you give consent to us processing your personal information for a specific purpose, you may withdraw your consent at any time. If you wish to exercise any of your rights, Contact Us. These rights may be limited in some situations — for instance, when we can demonstrate that we have a legal requirement to process your personal data.

Right to access: You have the right to obtain confirmation that your personal information is being processed and receive a copy of it, along with certain information related to its processing.
Right to correction: You can request the correction of your personal information that is inaccurate, as well as to have incomplete personal information completed. You can also change your personal information in your account at any time.
Right to deletion: In some cases, you may delete your personal information. To do this, if you have an account on the Platform, you can request the deletion of your personal information or its transfer to third parties through hello@mfpay.me
Right to object: For reasons related to your particular situation, you can object to the processing of your personal information. For example, you have the right to object when we rely on legitimate interests or when we process your data for direct marketing purposes.
Right to restrict processing: In certain circumstances, you have the right to temporarily restrict our processing of your personal information where there are valid grounds to do so. We can continue to process your personal information, if necessary, to defend against legal claims or for any other exceptions permitted by applicable law.
Right to data portability: In some instances, you can ask to receive your personal information that you have provided to us in a structured, commonly used, and machine-readable format, or, where feasible, have us transfer your personal information directly on your behalf to another data controller.
Right to withdraw consent: For processing that requires your consent, you have the right to withdraw your consent at any time. Exercising this right does not affect the lawfulness of processing based on consent given prior to its withdrawal.

Exercising Your Rights and Complaints
Your right to lodge complaints with the data protection authority in the country where you live or work or where you believe a violation has occurred remains intact.

International Data Transfers
Your information will be collected, processed, and stored directly:
For personal data from citizens of Europe and the UK, on servers at Hetzner.
For citizens of Russia, on servers at Yandex.
Furthermore, information may be transferred to other countries where the Platform or third-party business partners have facilities or business operations, which may include countries outside the UK or EU. In cases where we are legally required to apply appropriate security measures to protect your personal information, we use methods approved by the European Commission for this purpose.
As written above, we may collect Personal Data from customers located in the EEA. To facilitate services that we provide to customers residing in the EEA, we seek direct consent for the transfer of Personal Data out of the EEA. If you are an individual residing in the EEA and refuse to consent to such a transfer, you will no longer be able to use MFPAY LIMITED and our services. You will have the opportunity to withdraw your digital assets; however, all other functions will be disabled.
For each of the rights described above, please contact us at hello@mfpay.me.

11. Notice for Users Outside the United Kingdom, EU, and Russia
As stated in the "International Data Transfers" section, your information will be directly collected, processed, and stored on officially approved and secure servers or transferred to them, and may also be transferred to other countries where the Platform or our third-party business partners have facilities or business operations. Your personal information will be accessible to law enforcement and/or regulatory authorities in accordance with the laws of such countries.
Regardless of where the information is located, MFPAY LIMITED takes commercially reasonable measures to protect your privacy rights in accordance with this Privacy Policy. If you do not agree to the collection, processing, storage, and transfer of your information, please do not provide us with your information and cease using our Platform.

12. Contact Us
To contact us regarding this Privacy Policy only:
hello@mfpay.me
To contact us for other inquiries:
support@mfpay.me