Privacy Policy
Effective Date: 01 January 2020
Reviewed On: 01 January 2020
1. Policy Statement
This Privacy Policy ("Policy") outlines how ZoviPay Payment Solutions Ltd. ("ZoviPay", "we", "our", or "us") lawfully collects, processes, stores, and protects the Personal Data of individuals and businesses operating outside the jurisdiction of the United States of America. ZoviPay is committed to upholding international privacy principles in accordance with the General Data Protection Regulation (EU) 2016/679, the UK GDPR, and other applicable regional privacy laws.
2. Legal Basis for Processing
ZoviPay processes Personal Data in accordance with the following legal grounds:
Consent (where required and obtained clearly);
Contractual necessity (performance of services or onboarding processes);
Legal and regulatory obligation (e.g., anti-money laundering requirements);
Legitimate interests, provided such interests are not overridden by the fundamental rights and freedoms of the data subject.
3. Scope of Application
This Policy applies to:
Visitors accessing ZoviPay’s website or platform from non-U.S. territories;
Merchants and agents using ZoviPay services internationally;
Third parties providing services under agreement with ZoviPay outside the U.S.
This Policy does not apply to individuals or entities located within the United States.
4. Personal Data We Collect
We may collect and process the following categories of Personal Data:
Category Description
Identification Data Full name, passport/ID number, date of birth, nationality
Contact Data: Email, phone number, address, Telegram or WhatsApp ID
Business Data: Company name, legal registration documents, shareholder info
Financial Data: Bank account numbers, USDT wallet addresses, payment history
Technical Data: IP address, browser type, operating system, device fingerprint
Usage Data: Login history, transaction logs, activity timestamps
5. Collection Methods
Personal Data is collected through:
Direct submission via onboarding forms and communication;
Integration through APIs and partner platforms;
Use of cookies, analytics, and security monitoring tools;
Verification with third-party compliance services.
6. Purpose of Processing
We process Personal Data for the following legitimate and lawful purposes:
To verify identities and conduct KYC/AML checks;
To process payments, settlements, and disbursements;
To provide technical and customer support;
To comply with laws applicable to financial services and payment processing;
To enhance platform security, fraud detection, and risk management;
To improve platform performance and user experience.
7. Data Retention and Storage
ZoviPay retains Personal Data only for as long as necessary under applicable law or contractual requirements, generally:
maximum 5 months y from the end of the merchant relationship;
Longer when required for audits, investigations, or litigation.
Data is securely deleted or anonymized after expiration of the retention period.
8. Security Measures
ZoviPay implements rigorous technical and organizational safeguards, including:
AES 256-bit encryption for data at rest;
TLS 1.3 encryption for data in transit;
Multi-Factor Authentication (MFA) for system access;
Third-party vulnerability testing and monitoring.
9. International Data Transfers
ZoviPay may transfer Personal Data across borders, including to jurisdictions that may not provide the same level of data protection as the originating country. In such cases, we rely on:
Standard Contractual Clauses (SCCs) issued by the European Commission;
Binding Corporate Rules (where applicable);
Other lawful instruments approved by data protection authorities.
10. Data Subject Rights
In accordance with applicable non-U.S. privacy laws, you may have the following rights:
Right of access – obtain a copy of your data;
Right of rectification – correct inaccurate or outdated data;
Right of erasure – request deletion under lawful grounds;
Right to object – to certain processing activities;
Right to data portability – receive your data in a portable format;
Right to restrict processing – limit the use of your data under specific conditions.
You may exercise these rights by contacting [email protected]. Identity verification may be required.
11. Third-Party Processors and Disclosures
We may share your Personal Data with:
Acquiring banks, payment providers, and liquidity partners;
Regulatory or law enforcement authorities, under valid legal process;
Identity verification and sanctions screening providers;
Our attorneys, auditors, and consultants under confidentiality obligations.
We do not sell or monetize Personal Data under any circumstance.
12. Automated Decision-Making
ZoviPay may use algorithmic decision-making for fraud detection, transaction scoring, or account verification. However, such systems are regularly reviewed and do not result in legal or similarly significant consequences without human oversight.
13. Cookies and Analytics
Our website uses cookies for:
Security enhancement;
Session management;
Analytics (e.g., Google Analytics, device fingerprinting).
A full Cookie Policy is available and linked from our website.
14. Changes to the Policy
This Policy is reviewed annually and may be amended to reflect changes in legislation, technology, or ZoviPay operations. All updates will be published on our website with effective dates.
15. Contact Details and Complaints
For inquiries, complaints, or to exercise your rights:
Data Protection Officer (DPO)
Bit Xe Ai Limited
Email: [email protected]
Reviewed On: 01 January 2020
1. Policy Statement
This Privacy Policy ("Policy") outlines how ZoviPay Payment Solutions Ltd. ("ZoviPay", "we", "our", or "us") lawfully collects, processes, stores, and protects the Personal Data of individuals and businesses operating outside the jurisdiction of the United States of America. ZoviPay is committed to upholding international privacy principles in accordance with the General Data Protection Regulation (EU) 2016/679, the UK GDPR, and other applicable regional privacy laws.
2. Legal Basis for Processing
ZoviPay processes Personal Data in accordance with the following legal grounds:
Consent (where required and obtained clearly);
Contractual necessity (performance of services or onboarding processes);
Legal and regulatory obligation (e.g., anti-money laundering requirements);
Legitimate interests, provided such interests are not overridden by the fundamental rights and freedoms of the data subject.
3. Scope of Application
This Policy applies to:
Visitors accessing ZoviPay’s website or platform from non-U.S. territories;
Merchants and agents using ZoviPay services internationally;
Third parties providing services under agreement with ZoviPay outside the U.S.
This Policy does not apply to individuals or entities located within the United States.
4. Personal Data We Collect
We may collect and process the following categories of Personal Data:
Category Description
Identification Data Full name, passport/ID number, date of birth, nationality
Contact Data: Email, phone number, address, Telegram or WhatsApp ID
Business Data: Company name, legal registration documents, shareholder info
Financial Data: Bank account numbers, USDT wallet addresses, payment history
Technical Data: IP address, browser type, operating system, device fingerprint
Usage Data: Login history, transaction logs, activity timestamps
5. Collection Methods
Personal Data is collected through:
Direct submission via onboarding forms and communication;
Integration through APIs and partner platforms;
Use of cookies, analytics, and security monitoring tools;
Verification with third-party compliance services.
6. Purpose of Processing
We process Personal Data for the following legitimate and lawful purposes:
To verify identities and conduct KYC/AML checks;
To process payments, settlements, and disbursements;
To provide technical and customer support;
To comply with laws applicable to financial services and payment processing;
To enhance platform security, fraud detection, and risk management;
To improve platform performance and user experience.
7. Data Retention and Storage
ZoviPay retains Personal Data only for as long as necessary under applicable law or contractual requirements, generally:
maximum 5 months y from the end of the merchant relationship;
Longer when required for audits, investigations, or litigation.
Data is securely deleted or anonymized after expiration of the retention period.
8. Security Measures
ZoviPay implements rigorous technical and organizational safeguards, including:
AES 256-bit encryption for data at rest;
TLS 1.3 encryption for data in transit;
Multi-Factor Authentication (MFA) for system access;
Third-party vulnerability testing and monitoring.
9. International Data Transfers
ZoviPay may transfer Personal Data across borders, including to jurisdictions that may not provide the same level of data protection as the originating country. In such cases, we rely on:
Standard Contractual Clauses (SCCs) issued by the European Commission;
Binding Corporate Rules (where applicable);
Other lawful instruments approved by data protection authorities.
10. Data Subject Rights
In accordance with applicable non-U.S. privacy laws, you may have the following rights:
Right of access – obtain a copy of your data;
Right of rectification – correct inaccurate or outdated data;
Right of erasure – request deletion under lawful grounds;
Right to object – to certain processing activities;
Right to data portability – receive your data in a portable format;
Right to restrict processing – limit the use of your data under specific conditions.
You may exercise these rights by contacting [email protected]. Identity verification may be required.
11. Third-Party Processors and Disclosures
We may share your Personal Data with:
Acquiring banks, payment providers, and liquidity partners;
Regulatory or law enforcement authorities, under valid legal process;
Identity verification and sanctions screening providers;
Our attorneys, auditors, and consultants under confidentiality obligations.
We do not sell or monetize Personal Data under any circumstance.
12. Automated Decision-Making
ZoviPay may use algorithmic decision-making for fraud detection, transaction scoring, or account verification. However, such systems are regularly reviewed and do not result in legal or similarly significant consequences without human oversight.
13. Cookies and Analytics
Our website uses cookies for:
Security enhancement;
Session management;
Analytics (e.g., Google Analytics, device fingerprinting).
A full Cookie Policy is available and linked from our website.
14. Changes to the Policy
This Policy is reviewed annually and may be amended to reflect changes in legislation, technology, or ZoviPay operations. All updates will be published on our website with effective dates.
15. Contact Details and Complaints
For inquiries, complaints, or to exercise your rights:
Data Protection Officer (DPO)
Bit Xe Ai Limited
Email: [email protected]