Effective date: April 7, 2023

Cheq Payments UAB (“Pay.so Core,” “we,” “our,” and/or “us”) values the privacy of individuals who use our website and related online services (collectively, our “Services”). This privacy policy (the “Privacy Policy”) explains how we collect, use, and share information from users of our Services to fulfil crypto-to-fiat payments. It applies to information collected from our website visitors and business customers (collectively, “Customers”, “you”, and/or “your”).  By using our Services, you agree to the collection, use, disclosure, and procedures this Privacy Policy describes. Beyond the Privacy Policy, your use of our Services is also subject to our Terms of Service [link to terms of service]. This Privacy Policy does not apply to information that we process as a service provider on behalf of our business customers.

INFORMATION WE COLLECT

We may collect a variety of information from or about you or your devices from various sources, as described below.

Information You Provide to Us

• Registration and Profile Information. When you establish an account with us, we ask you for your full legal name and email address. Should you want to utilise our services for fiat transfers, we will need to perform a further KYC/KYB check including but not limited to the collection of you or your company’s proof of address, photographic ID, and shareholder documentation.
• Communications. If you contact us directly, we may receive additional information about you. For example, if you contact us for customer support, we may receive your name, email address, phone number, the contents of the message and any attachments you send to us, and any other information you choose to provide. If you subscribe to our newsletter, we will collect certain information from you, such as your email address. When we send you emails, we may track whether you open them to learn how to deliver a better customer experience and improve our Services.
• Careers. If you decide that you wish to apply for a job with us, you may submit your contact information and your resume online. We will collect the information you choose to provide on your resume, such as your education and employment experience. You may also apply through LinkedIn. If you do so, we will collect the information you make available to us on LinkedIn.
• Payment Information. If you make a purchase through our Services, your payment-related information, such as credit card, cryptocurrency wallet address, or other financial information, is collected by us or a third party payment processor on our behalf.
• Identity Verification Information. We or a third party acting on our behalf may collect your government issued identity document such as Passport, Driver's License, National Identity Card, State ID Card, Tax ID number, passport number, driver's license details, national identity card details, visa information, and/or any other information deemed necessary to comply with our legal obligations under financial or anti-money laundering laws.

Information We Collect When You Use Our Services

• Financial information. To make it possible to fulfil transactions, we will ask you to provide the details of recipient bank accounts (such as account number, routing number). Additionally we may ask you for a reference message to describe the transaction. Sometimes to satisfy our efforts in fighting money laundering, we may ask questions surrounding the nature of the transaction before we can fulfil it. There may also be information that we collect that is not explicitly shared with us but can be inferred, such as the address of the crypto-currency wallet from which we received funds. Such information may be used for operational purposes or sometimes considered as a data point to mitigate the risk of financial crime on the platform.
• Usage Information. On our website, to help us understand how you use our Services and to help us improve them, we automatically receive information about your interactions with our Services, such as the pages or other content you view and the dates and times of your visits. On our API, we analyse usage of our endpoints and behavioural pattens both for analytical purposed and for consideration in detecting signs of terms violation or financial crime.
• Information from Cookies and Similar Technologies. On our website, we and third party partners collect information using cookies, pixel tags, or similar technologies. Our third party partners, such as analytics and advertising partners, may use these technologies to collect information about your online activities over time and across different services. Cookies are small text files containing a string of alphanumeric characters. We may use both session cookies and persistent cookies. A session cookie disappears after you close your browser. A persistent cookie remains after you close your browser and may be used by your browser on subsequent visits to our Services. Please review your web browser’s “Help” file to learn the proper way to modify your cookie settings. Please note that if you delete or choose not to accept cookies from the Service, you may not be able to utilize the features of the Service to their fullest potential.

HOW WE USE THE INFORMATION WE COLLECT

We may use the information we collect:

• To provide, maintain, improve, and enhance our Services;