Privacy Policy

Legal basis for the processing

Categories of the Data concerned

Is the provision of the Data a requirement?

Contract

(Article 6(1)(b) of GDPR)

Legal obligation

(Article 6(1)(c) of GDPR)

Name and surname, personal identification data (where applicable), date of birth, nationality, e-mail address, telephone number, residential or business address, represented entity (where applicable), company position, payment account details (including IBAN), customer identification number, authentication data, payment instrument information, payment transaction details (including payer and payee information, transaction amount, currency, date, reference and transaction identifiers) 

Yes – this is a contractual requirement. If you do not provide the required Personal Data, we may be unable to establish a business relationship with you, open or maintain your payment account, or provide the requested electronic money and payment services

Legal basis for the processing

Categories of the Data concerned

Is the provision of the Data a requirement?

Legal obligation

(Art. 6(1)(c) of GDPR)

Name, surname, personal identity number, photograph, gender, country, city, date of birth, identity document data (photo, expiry date, copy of the document), signature, nationality/citizenship, bank account number, payment type, payment purpose/fee title, transaction ID, payer code, payment code, time, amount, place, data required to implement measures for AML/CFT, tax evasion prevention and international sanctions

Yes – this is a statutory requirement. If you do not provide this data, we will not be able to provide our services

Processing is necessary for reasons of substantial public interest 

(Art. 9(2)(g) of GDPR)

Information whether you are a politically exposed person (PEP)

Legal basis for the processing

Categories of the Data concerned

Is the provision of the Data a requirement?

Consent 

(Article 6(1)(a) of GDPR)

Legitimate interest (to handle your inquiries (Article 6(1)(f) of GDPR)

Name, surname, e-mail address, telephone number, residential or business address, the content of the inquiry, request, or complaint, information and documents related to the submitted inquiry, request, or complaint, responses, correspondence records, chat transcripts, and any other information voluntarily provided by you in the course of communication

No

Legal basis for the processing

Categories of the Data concerned

Is the provision of the Data a requirement?

Consent 

(Article 6(1)(a) of GDPR)

Legitimate interest (to inform you about our services and goods) (Article 6(1)(f) of GDPR)

Customer relationship (Article 13(2) of the e-Privacy Directive 2002/58/EC)

Name and surname, e-mail address, telephone number, demographic information (age, gender, location, language preferences), communication preferences and consents, social media identifiers and usernames, profile information (profile photo, description, public interests), comments, reactions, messages sent to us, our replies to your messages, participation in surveys, promotions, contests, reviews, testimonials, and events, browsing behavior on our websites and apps, interactions with marketing communications, device and technical data (IP address, device type, operating system, browser type, advertising identifiers, cookies, pixel tags, and similar technologies), geolocation data (if enabled), social media engagement statistics, ratings

No

Legal basis for the processing

Categories of the Data concerned

Is the provision of the Data a requirement?

Legitimate interest 

(to ensure the security, proper functioning, and continuous improvement of the website, mobile application, and products) (Article 6(1)(f) of GDPR)

IP address, device identifiers, device type and model, operating system and version, browser type and version, screen resolution, language settings, time zone, login data, session identifiers, cookies and similar tracking technologies, browsing and interaction data on the website, in the mobile app, and with product features, referrer URL, geolocation data (if enabled), network and connection information, log files, error and crash data, authentication and access records, user account activity (including login attempts), order history (to detect suspicious or unusual activity), feedback and in-app behavior related to product usage

No

Legal basis for the processing

Categories of the Data concerned

Is the provision of the Data a requirement?

Consent 

(Article 6(1)(a) of GDPR)

Legitimate interest to contact you regarding job opportunities in our company 

(Article 6(1)(f) of GDPR)

Name, surname, place of residence or residential address, e-mail address, telephone number, information about work experience (employer, period of employment, position, responsibilities, achievements), information about education (educational institution, period of study, degree and/or qualification obtained), information about training (courses attended, certificates obtained), information about language skills, IT skills and other competences, other information provided in the CV, cover letter or other application documents, name of the referee/recommending person, content of the recommendation, summary of the interview, notes and opinions of the recruiter, results of candidate testing

No

Legal basis for the processing

Categories of Data concerned

Is the provision of the Data a requirement?

Legal obligation

(Article 6(1)(c) of GDPR)

Legitimate interest in protecting our rights and legal interests

(Article 6(1)(f) of GDPR)

Name, surname, email address, contracts, legally binding documents and data, correspondence, legal documents, pleadings, annexes, court documents, investigative information, information about convictions and criminal offences, logs, possible breaches and incidents, and any other information provided and collected

When the processing of your Data is required under applicable laws, providing this data becomes a legal necessity. If you are unable to provide this data, unfortunately, we will not be in a position to offer our services to you

Source of origin of data

Purpose of processing

Our clients 

To provide our services 

Payment service providers

Processing and confirming payments

Social media service providers

Managing our social media profiles

Recruitment agencies, job search portals, professional social networks (e.g. LinkedIn) 

Recruitment

Registers of legal entities

To comply with applicable legislation

Publicly available sanctions, politically exposed persons (PEP), adverse media and other compliance-related databases, lists and information sources.

To ensure compliance with AML, CTF and fraud prevention requirements

Public records databases (such as company registries and regulatory filings) and information obtained from publicly available sources through open-source intelligence (OSINT) activities

To ensure compliance with AML, CTF and fraud prevention requirements

We and/or our third-party verification providers may collect information from private or commercially available sources, including credit reference agencies, fraud prevention agencies and other verification providers, to the extent permitted by applicable law

To ensure compliance with AML, CTF and fraud prevention requirements

Supervisory authorities, police, prosecutors, courts, law enforcement and other state and municipal authorities, participants in legal proceedings and their representatives

Compliance with legal requirements and defence of our legal interests

Recipients or categories of recipients

If the Data are to be transferred 

to a third country or an international organisation:

Third country

Safeguard measure or exemption allowing the transfer

Credit reference, fraud protection, risk management, and identity and verification agencies

—

Participants in the transaction processing chain (merchants, acquirers, banks or other card issuers, card associations)

—

Lawyers, notaries, bailiffs, data protection officers, auditors, tax, business, HR and other consultants

—

Providers of IT tools and services, electronic communications service providers, travel agencies, insurance companies, archiving and other service providers

—

State labour, social security, tax, supervisory authorities, police, prosecutors, courts, law enforcement and other state and local authorities 

—

Elcoin LTD (banking service provider)

UK

Adequacy Decision 

AMLWatcher.com LLC (customer due diligence (KYC), transaction monitoring and compliance service provider)

USA

EU Standard Contractual Clauses

Facebook (Meta) (social media service provider)

USA

EU Standard Contractual Clauses

LinkedIn (social media service provider)

USA

EU Standard Contractual Clauses

Microsoft Corporation (provider of cloud, productivity and IT infrastructure services)

USA

EU Standard Contractual Clauses

Potential or actual purchasers of the business or part of it and their authorised advisers or representatives

Various

EU Standard Contractual Clauses

My right

Summary

Right of access

The right to obtain confirmation from us as to whether Data relating to you is being processed and, if such Data is being processed, the right to have access to the Data and information about the processing.

Right to rectification

The right to require us to rectify inaccurate Data relating to you.

Right to erasure (‘right to be forgotten’)

– when Data are no longer necessary in relation to the purposes for which they were collected or otherwise processed;

– when you withdraw consent on which the processing of Data is based and there is no other legal ground for the processing;

– when you object to the processing of Data and there are no overriding legitimate grounds for the processing, or you object to the processing for direct marketing purposes;

– where the Data have been unlawfully processed;

– where the Data have to be erased for compliance with a legal obligation;

– where the Data have been collected in relation to the offer of information society services directly to a child and subject to a consent.

Right to restriction of processing

– where the accuracy of the Data is contested by you;

– where the processing of Data is unlawful and you oppose the erasure of the Data and request the restriction of their use instead;

– where we no longer need the Data for the purposes of the processing, but they are required by you for the establishment, exercise or defence of legal claims;

where you have objected to the processing of the Data and until it has been verified whether our legitimate interests override yours.

Right to data portability

where you seek to receive the Data you have provided in a structured, commonly used and machine-readable form or to transmit those data to another controller, the processing is based on consent or on a contract and is carried out by automated means.

Right to object

where the collection and use of the Data is based on a task carried out in the public interest or in the exercise of official authority vested or legitimate interest, including profiling, as explained in Section 3 of this Privacy Policy, or where you object to the collection of your data for direct marketing purposes.

Right to withdraw consent

where the processing of Data is based on consent, as explained in Section 3 of this Privacy Policy, and you seek to withdraw it at any time.

Right to lodge a complaint

Right to lodge a complaint with a supervisory authority

Purpose of processing

Cookie

Category

Whether third parties will have access to the information

Duration of operation

A first-party session cookie likely used by the website application to maintain temporary state during a browsing session (e.g., routing, session continuity, anti-bot/session integrity, or keeping transient user flow data). Because it is session-scoped (expires at end of session) and the name is not a widely documented standard, the exact function cannot be confirmed from the name alone, but it is typically used to ensure core site functionality during navigation.

Application Session / State Cookie (TURTLE)

Strictly Necessary

No

Session

A first-party session cookie likely used to store an inferred or selected geographic region (e.g., country/region) to deliver localized content, comply with regional rules, or route the user to the appropriate experience. If used purely for localization (language/region display) it is functional; if used for access control or regulatory gating it may be necessary. With only the cookie name available, the most typical use is localization.

Geolocation / Region Preference Cookie

Functional

No

Session

Used by the i18next internationalization framework to remember the user’s selected language/locale so the site can display content in the preferred language across pages during the session.

Language Preference Cookie (i18next)

Functional

No

Session

Set by AWS Elastic Load Balancing to maintain session stickiness to a specific target behind the load balancer. This helps ensure requests from the same user are consistently routed to the same backend instance, improving reliability and preventing session-related errors.

AWS Load Balancer Stickiness Cookie (Target Group)

Strictly Necessary

No

7 days

A variant of the AWS load balancer stickiness cookie used in cross-origin contexts. It supports consistent routing (session affinity) when requests are made in scenarios involving CORS, helping core site functionality remain stable.

AWS Load Balancer Stickiness Cookie (Target Group, CORS)

Strictly Necessary

No

7 days

Set by AWS Elastic Load Balancing to route a user’s requests consistently to the same backend server during a period of time. This is commonly required for stable operation of login flows, multi-step forms, and other session-dependent features.

AWS Load Balancer Stickiness Cookie

Strictly Necessary

No

7 days

CORS-compatible version of the AWS load balancer cookie that supports session affinity in cross-origin request scenarios, helping ensure reliable delivery of the website and its services.

AWS Load Balancer Stickiness Cookie (CORS)

Strictly Necessary

No

7 days