Politique de confidentialité

1. Definitions

“You” / “your” / “yours” / “customer” means a natural person who has opened an account on Paycot.com, has agreed to all terms and conditions of Paycot.com, and wishes to use the Services available on the Platform.

“Paycot” means PAYCOTCOM SPÓŁKA Z OGRANICZONĄ ODPOWIEDZIALNOŚCIĄ, a limited liability company (registration No. 0001025475) incorporated in Poland, with its registered office at ul. Władysława Reymonta 15/1, 60-791 Poznań, POLAND.

“Personal Information” means any information relating to an identified or identifiable natural person, as defined under the General Data Protection Regulation (GDPR), which allows Paycot to verify your identity and fulfill its regulatory obligations.

“Services” means the services provided by Paycot, including: (1) selling cryptocurrency to the customer in exchange for fiat currency; and (2) buying cryptocurrency from the customer for fiat currency. Paycot does not provide Services to corporate customers and does not act as a custodian for your funds, both crypto and fiat.

2. Main principles

• Data Controller and Processor: Paycot acts as both the controller and processor of your Personal Information. Only authorized employees of Paycot have access to your data.
• Contact Details of the Controller:
  • Company Name: PAYCOTCOM SPÓŁKA Z OGRANICZONĄ ODPOWIEDZIALNOŚCIĄ
  • Registered Address: ul. Władysława Reymonta 15/1, 60-791 Poznań, POLAND
  • Contact Email: [email protected]
• Data Protection Officer (DPO): If applicable, Paycot will appoint a Data Protection Officer. You may contact the DPO at [email protected]
• Legal Basis for Processing: Paycot processes Personal Information based on the following legal grounds under Article 6(1) GDPR:
  • (a) Consent – when you voluntarily provide your data; Marketing;
  • (b) Contractual necessity – to provide you with our Services;
  • (c) Legal obligation – to comply with regulatory requirements;
  • (f) Legitimate interests – for fraud prevention, security, and service improvement.
• Legitimate Interests Pursued: When processing is based on legitimate interests, Paycot ensures that such interests do not override your fundamental rights and freedoms.
• Data Protection Measures: Paycot employs encryption, legally binding contractual clauses, and other technical and organizational measures to protect your Personal Information.
• International Data Transfers: Paycot collaborates with entities worldwide, which may require the transfer of your Personal Information to jurisdictions outside the European Union. In such cases, Paycot ensures that appropriate safeguards (such as Standard Contractual Clauses) are in place to protect your data.
• Changes to the Privacy Policy: Paycot reserves the right to modify this privacy policy at any time. If significant amendments are made, you will be notified before the changes take effect. Continued use of the Services after changes have been published constitutes your acceptance of the revised policy.

This privacy policy regulates how Paycot:

• Collects your Personal Information;
• Protects your Personal Information;
• Uses the obtained Personal Information;
• Discloses your Personal Information to third parties;
• Allows you to correct, update, or delete your Personal Information upon request.

For inquiries or requests regarding your Personal Information, you can contact us at:
[email protected]

3. Collection of Personal Information

Paycot collects your Personal Information as soon as you begin using the Services. In compliance with regulatory requirements, Paycot may collect the following data:

• First name, middle name, and last name;
• Date and place of birth;
• Phone number;
• Email address;
• Residential address;
• Government-issued identification documents;
• Proof of address;
• Payment details;
• Any other information necessary to comply with regulatory requirements.

Purposes of Processing Personal Information:

• Providing uninterrupted access to the Services;
• Processing your requests and communications;
• Analyzing customer activity on Paycot.com;
• Meeting legal and regulatory requirements.
• Ensuring business continuity.
• Marketing
  
  

4. Sources of Personal Information

Paycot obtains your Personal Information from various sources, including but not limited to:

• Information provided directly by you during registration and account verification;
• Third-party service providers (e.g., identity verification services, anti-money laundering (AML) monitoring tools);
• Cryptocurrency blockchains;
• Payment service providers.
  
  

5. Disclosure of Personal Information to Third Parties

To provide our Services and comply with regulatory requirements, Paycot may share your Personal Information with third parties, including identity verification providers, blockchain analytics firms, financial institutions, and regulatory authorities. Depending on your location and the nature of the services required, your data may be processed by entities such as identity verification providers, compliance and risk assessment firms, or financial intelligence units operating in relevant jurisdictions. Paycot works with trusted partners, including but not limited to providers of identity verification, transaction monitoring, and compliance solutions. These partnerships may involve entities operating under applicable data protection regulations in various regions, ensuring that your Personal Information is processed securely and in accordance with relevant legal frameworks. When required, Paycot takes necessary measures to ensure that any data transfers comply with regulatory safeguards, such as Standard Contractual Clauses or equivalent mechanisms.

Paycot may disclose your Personal Information to:

• Paycot Group (parent companies, subsidiaries, branches, affiliates, agents);
• Third-party service providers (e.g., identity verification providers, blockchain monitoring tools, payment processors, card-issuing and acquiring banks);
• Law enforcement and regulatory authorities upon a valid legal request.

Paycot ensures that all third parties processing your Personal Information adhere to data protection standards equal to or higher than those of Paycot.

In order to facilitate the provision of services and ensure compliance with applicable regulations, Paycot may transfer your Personal Information to our partner, Vemopay Inc., located in Canada. This transfer is necessary for the execution of services that we provide, such as payment processing and identity verification. Paycot takes all appropriate measures to ensure that such transfers are carried out in accordance with applicable data protection laws, including the use of Standard Contractual Clauses and other safeguards to protect your data.

6. Data Retention and Your Rights

Retention Period: Paycot retains Personal Information only for as long as necessary to fulfill the purposes outlined in this privacy policy and to comply with legal and regulatory requirements.

Your Rights:

• Right of Access: You can request details about the Personal Information we process about you.
• Right to Rectification: You can request the correction of inaccurate or incomplete data.
• Right to Erasure: You can request the deletion of your Personal Information, subject to legal retention requirements.
• Right to Restrict Processing: You can request that we limit the processing of your data under certain conditions.
• Right to Data Portability: You have the right to receive your Personal Information in a structured, commonly used format.
• Right to Object: You can object to the processing of your data for direct marketing purposes.
• Right to Withdraw Consent: If processing is based on consent, you can withdraw it at any time.
• Right to Lodge a Complaint: If you believe your data protection rights have been violated, you can file a complaint with a data protection authority in your country.

To exercise your rights, contact us at [email protected].

7. Marketing

For the purpose of carrying out advertising, marketing and publicity activities, Paycot may process and store, for the entire duration of data storage according to this Privacy Policy, personal data, obtained based on forms, declarations and documents of any kind submitted, drafted or completed, necessary to contact you in order to promote our own products, services, as well as to increase our brand awareness.

In this context, data subjects have the right to withdraw their consent to receive marketing information, without any justification, free of charge, in writing, by email to [email protected]. or by registered letter with acknowledgement of receipt, that their personal data will not be processed by Paycot for advertising, marketing and publicity purposes and/or for the performance of financial activity or will not be disclosed to third parties for such purposes.

8. Automated Decision-Making and Profiling

Paycot does not engage in automated decision-making or profiling that would have significant legal or similarly substantial effects on you.

9. Security Measures

Paycot implements robust security measures to protect your Personal Information, including:

• Data encryption in transit and at rest;
• Two-factor authentication for account security;
• Regular security audits and risk assessments;
• Strict access controls and employee training on data protection.
  
  

10. Cookies and Tracking Technologies

Paycot uses cookies and similar tracking technologies to enhance user experience and analyze website traffic. More information is available here [link to the Cookie Policy].

11. Contact Information

If you have any questions or concerns regarding this privacy policy or your Personal Information, please contact us at:

Email: [email protected]

Address: PAYCOTCOM SPÓŁKA Z OGRANICZONĄ ODPOWIEDZIALNOŚCIĄ, ul. Władysława Reymonta 15/1, 60-791 Poznań, POLAND.

This privacy policy is effective as of the date of publication and supersedes all previous versions.