Welcome to the Privacy Policy (the “Policy“).

This Website and Mobile application are owned by the company TrustPay AI Systems Ltd, incorporated in the United Kingdom with a registered number 14788124 and registered office at 45 Albemarle Street, Mayfair, London, W1S 4JL (“TrustXPay“).

Choise Services UAB, a legal entity duly registered in Lithuania with No. 305964183 with a registered office at Vokieciu gatve 18a-7, Vilnius (the “Choise“) and Charism LLC, is a limited liability company created and existing under the laws of Saint Vincent and Grenadines, with company number 1999 LLC 2022, registered office at Suite 336, Beachmont Business Centre, Kingstown (the “Associated company“).

As a high-level summary, we are an evolving cryptocurrency-focused financial institution providing various cryptocurrency-related financial services (the “Services“). We provide all this employing the website https://www.trustxpay.com/ (the “Website“) and the related mobile application and crypto-platforms that we may operate from time to time (each of which, is a “Platform“) and which may be accessible via the Website or otherwise.

Accordingly, the purpose of this Policy is to set out the basis on which we will process your data when you:

  1. visit and use a Website and/or Platform, regardless of where you visit or use them from;
  2. apply for and register a customer account with us (your “Account”);
  3. apply for, receive, pay, and/or use any of our Services.

This also includes any data that you may provide to us for our events, newsletters, and other marketing items.

This Policy informs you about the items of Personal data that we may collect about you and how we will handle it, and in turn, also tells you about
(i) our obligations to process your data responsibly,
(ii) your data protection rights as a data subject, and
(iii) how the law protects you.

It should be read in conjunction with our Cookie Policy.

Please read the following information carefully to understand our practices regarding your data.
Important information and who we are

General Data Protection Regulation (Regulation (EU) 2016/679) (GDPR) regulations shall be implemented for EU users (the “Regulation” or the “GDPR”).

This Policy aims to ensure that you are fully informed on how we will collect and
process your Personal data in the circumstances and scenarios outlined in the ‘Introduction’ (namely, through your token subscriptions and purchases, your use of the Website, and any of the related Services).

The Websites, the Platform, and the Services are not intended or in any way made available for minors, and we do not knowingly collect data relating to minors. You must read this Policy together with any other privacy or fair processing notice we may provide on specific occasions when we are collecting or processing Personal data about you so that you are fully aware of how and why we are using your data. This Policy supplements the other notices and is not intended to override them.

The opening and registration of a customer account will give rise to the existence of a contractual relationship with us, as regulated by our Terms of Use, and all matters between you and us relating to Services will be deemed to fall within the subject matter of that same contractual relationship. Furthermore, the existence of this contract between you and us will also serve as the legal basis for a number of our processing activities involving your Personal data, as detailed below.

Controllers

TrustPay AI Systems Ltd (as defined) above is the controller and is responsible for your Personal data. There may be other controllers of your Personal data, such as, for example, electronic identification verification service providers, Associated companies, or other service providers engaged by us for purposes of processing and storing your Personal data. They will be so-called “joint controllers” of your Personal data and as such, will share responsibility for
such control with us.

Presently, we use the services of the following service providers:

  • Ondato: https://www.ondato.com for KYC/AML verification;
  • Vero: https://www.getvero.com for handling e-mail lists and campaigns.

Please familiarize yourself with these providers and their privacy and liability policies. If you find any of these may not work for you, please do not access any of the Websites and do not use any of our Services.

As a general rule, we always seek to minimize the amount of your Personal data that we collect and store.

Contact details

Full name of legal entity: TrustPay AI Systems Ltd
Email address: privacy@trustxpay.com
Please use the words ‘Data Protection Matter’ in the subject line.

Changes to the Policy and your duty to inform us of changes

It is imperative that the Personal data we hold about you is accurate and current at all times. Otherwise, this will impair our ability to process your token purchases and/or our ability

to provide you with the Services that you may request from us (amongst other salient issues).
Please keep us informed if any of your Personal data changes during your relationship
with us.

Third-party links

Our Website may include links to third-party websites, plug-ins, and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy notice or policies. We strongly encourage you to read the privacy notice of every website you visit, particularly when leaving our Website.

  • “Consent Form” refers to separate documents that we might from time to time provide you where we ask for your explicit consent for any processing that is not for purposes set out in this Policy.
  • “Data subjects” means living individuals (i.e. natural persons) about whom we collect and process Personal data.
  • “Data controller” or “controller” means any entity or individual who determines the purposes for which, and how, any Personal data is processed.
  • “Data processor” or “processor” means any entity or individual that processes data on our behalf and on our instructions (we being the data controller).
  • “Personal data” means data relating to a living individual (i.e. natural person) who can be identified from the data (information) we hold or possess. This includes but is not limited to, your name and surname (including maiden name where applicable), address, date of birth, nationality, gender, civil status, tax status, identity card number & passport number, contact details (including mobile and home phone number and personal email address), photographic image, bank account details, emergency contact information as well as online identifiers. The term “personal information”, where and when used in this Policy, shall have taken the same meaning as Personal data.

Complaints

You have the right to complain at any time to a competent supervisory authority on data protection matters, such as (in particular) the supervisory authority in the place of your habitual residence or your place of work.

We would, however, appreciate the opportunity to deal with your concerns before you
approach the supervisory authority, so please contact us in the first instance at
privacy@trustxpay.com

11. Conclusion

We reserve the right to make changes to this Policy in the future, which will be duly
notified to you. If you have any questions regarding this Policy, or if you would like to send us your comments, please contact us today or alternatively