Privacy Notice
Scope
This Privacy Notice (“Notice”) describes the ways Alphacom Sp. z o.o. (“AFIPAY”, “we”, “us”, “our”) collects, stores, uses and protects information. AFIPAY’s services include merchant processing services, websites, mobile applications, products, and any other features, technologies or functionalities, including customer support (“Services”) offered by us. This Notice applies to AFIPAY.io and all other AFIPAY sites on which it appears (the “Sites”).
Depending on the jurisdiction in which you reside, you may be entitled to additional disclosures. For EU residents, please review our EU Privacy Notice.
We process personal information from the following types of users:
- Visitors of our Sites;
- Merchants who sign up for our Services;
- Shoppers who make transactions using AFIPAY;
- AFIPAY cardholders;
- AFIPAY wallet holders;
- Payees who request payments via cryptocurrency.
What Kind of Personal Information Do We Collect?
We collect personal information from you through your use of the Sites and Services. Personal information is information that is linked or reasonably linkable to an identified or identifiable individual. We collect different kinds of personal information depending on how you interact with our Sites and Services. The personal information we collect also depends on what type of user you are. In addition to personal information you choose to provide to us when interacting with our Services, we may also collect personal information automatically from your devices.
Visitors of our website
We may collect the following information relating to visitors of our Sites:
- If you create an account, you provide us with:
- Full Name
- Email Address
- Password
- When you sign into your account, you will provide us with:
- Login Credentials (password and email address)
- If you sign up to receive our blogs or other marketing materials, you will provide us with:
- Full Name
- Email Address
- If you contact our customer support, sales team, media team, or opt-in to our media list, you will provide us with:
- Full Name
- Email Address
- Phone Number
- Country of Residence
- We also collect information about a visitor’s computer or other access devices, including for purposes of fraud prevention. The information we collect may be collected automatically using cookies or other similar technologies. This information includes technical information such as your IP address, the type of browser, devices and operating systems you use, identifiers associated with the device(s) you use to access our Sites, the pages you visit and the features you use, access dates and times, if you navigated from or navigate to another website, the address of that website, and information regarding your internet service provider.
Merchants
In order to complete the onboarding process, we collect the personal information described below of the beneficial owner or any user that is added to an account of a Merchant (including nonprofits and Aggregators that use our Services as a payment services platform for their own Merchants). In the case of Aggregators, we collect the information of that Aggregator’s Merchants. The elements we collect depend on our compliance analysis and your risk profile, but generally include:
- Full name of beneficial owner
- Full names of authorized users
- Merchant email address
- Physical Address of Merchant or Aggregator primary place of business
- Business phone number
- Personal identification number of beneficial owner and authorized user(s) (e.g., driver’s license, government ID)
- Tax identification number (if applicable in specific country)
- Proof of business
- Proof of address
- Recent bank statements or bank letter of good standing
- Bank account details
In addition to completing the onboarding process, we may use this information for risk management purposes (i.e. to verify Merchant’s identity or address) or to comply with laws and regulations, including those applicable to financial services institutions. We may also obtain information about our Merchants from third parties that provide identity verification and fraud prevention services, such as Bureau Van Dijk, and from relevant Aggregators.
Shoppers
We collect personal information when a Shopper indirectly interfaces with AFIPAY to pay a Merchant’s invoice, request a refund, and/or make donations. We collect personal information from Shoppers for the following purposes:
- When you pay an AFIPAY invoice, we collect the following types of personal information:
- Technical information including IP addresses used to view the AFIPAY invoice
- Products purchased
- Price at the relevant Merchant
- Email address
- Crypto wallet address
- When you request a refund, we collect the following types of personal information:
- Amount to be refunded
- Currency in your location
- Email address
- Crypto wallet address
- Invoice number
- When you make a donation, we may collect, depending on the circumstances, the following types of personal information:
- Amount of donation
- Currency in your location
- Email address
- Full name
- Postal Address
- Phone number
- Employer
- Job title
- City of employment
- When you make an account, we will collect the following types of personal information:
- Full Name
- Email Address
- Email address
- Crypto wallet address
- Password
We collect this information either from the Merchant or directly from the Shopper. Collecting this information supports our ability to provide our Services. This enables our system to send an email to Shoppers directly to obtain a cryptocurrency refund address in case of a payment exception (e.g. overpayments, underpayments, etc.). This also creates a more seamless payment experience for both the Merchant and the Shopper. Additionally, upon the Merchant’s explicit request, we collect and store information for the Merchant’s benefit only and as a service through our invoicing service. Information that Merchants may request about Shoppers may include:
- Name
- Postal Address
AFIPAY Cardholder:
When you sign-up for and process payments through BitPay payment cards, we collect personal data in connection with such activities to complete your payment card registration, process your payments, refund a payment, or contact you regarding your payment card. The following personal information may be collected:
- Full Name
- Postal Address
- Date of birth
- Phone number
- Email address
- Tax number
Technical information, including IP address; the type of browser, devices and operating systems you use; identifiers associated with the device(s) you use to access our sites; the pages you visit and the features you use; access dates and times; and if you navigated from or navigate to another website, the address of that website; and information regarding your internet service provider
Wallet Holder:
AFIPAY offers a non-custodial wallet that permits individuals to manage payments in different currencies. To register and manage this portion of the Services, we collect the following information:
- Email address
- Wallet name
- Copayer name
- Co-payer name
- Wallet public key
- Wallet extended public key
- Wallet coin
- Wallet multi-sig setup
- Transaction details
- Type of mobile phone, OS and version, App version
- IP address
- Wallet ID (Client ID)
- App Token
- API Authentication Token
Payees of the Merchant:
AFIPAY offers a service for Merchants to pay individuals (employees, contractors, vendors, and exchange customers) via cryptocurrency (“Payees”). In order to provide this portion of the Services, the following information may be collected from Payees in certain instances:
- Full name
- Email address
- Wallet address/provider
- Personal identification documents (such as a passport or a driver’s license)
- Proof of address document (such as a bank statement or a utility bill)
Additional:
Through your use of the Sites and Services, we collect information regarding the effectiveness of our email and other communications. For example, we may know if you follow a link in an email we send to you. We may also obtain information about you from other third parties, such as information about your use of this Site or our Services. We may also collect information about former, existing, and prospective vendors and customers (“Partners”). This includes limited personal information about employees and agents of such Partners (“Partner Employees”) at the beginning and throughout the course of the Partner relationships, such as professional contact information.
How We Use Cookies
We may collect information about your activities on our Sites via first and third-party cookies, clear GIFs or web beacons, or through other identifiers or technologies, including similar technologies as they may evolve over time. We refer to these technologies collectively as cookies.
We may allow third parties to use cookies on our sites. The information collected by cookies may be shared with and used by us, by others acting on our behalf, or by third parties subject to their own privacy policies. Information collected by cookies may be used on this website or on other websites or services, including those that may not be operated by us. Other parties may collect personal information about an individual consumer’s online activities over time and across different websites when a consumer uses our Sites or Services.
Why We Collect Personal Information
In addition to the specific purposes provided in the preceding sections, we use the personal information we collect to operate our business, provide our Services, for other purposes as permitted or required by law, and to provide you with a smooth, efficient, and customized experience. Specifically, we may use your information to:
- Provide our Services (including customer support);
- Process transactions and send notices about your transactions;
- Resolve disputes, collect fees, and troubleshoot problems;
- Communicate with you about our Services and business and to inform you of matters that are important for your account and/or use of the Sites. We also use your personal data to respond to any questions, comments or requests you filed with us and the handling of any complaints;
- Comply with applicable laws and regulations;
- Establish, exercise and defend legal claims;
- Monitor and report compliance issues;
- Customize, measure, and improve our business, the Services, and the content and layout of our website and applications (including developing new products and services; managing our communications; determining the effectiveness of our sales, marketing and advertising; analyzing and enhancing our products, services, Sites and apps; ensuring the security of our networks and information systems; performing accounting, auditing, invoicing, reconciliation and collection activities; and improving and maintaining the quality of our customer services);
- Preform data analysis;
- Deliver targeted marketing, service update notices, and promotional offers based on your communication preferences, and measure the effectiveness of it. To approach you via email for marketing purposes, we request your consent, unless it is not required by law. You always have the option to unsubscribe from our mailings, e.g., via the unsubscribe link in our newsletter;
- Perform risk management, including comparing information for accuracy and verify it with third parties and protect against, identify and prevent fraud and other prohibited or illegal activity, claims and other liabilities; and Enforce our contractual terms.
How We Protect and Store Personal Information
We take the security of our information seriously. We use administrative, technical, and physical security designed to safeguard personal information in our possession, and we maintain internal policies and procedures to address our data security. However, no security measure or modality of data transmission over the internet is 100% secure. Although we strive to use commercially acceptable means to protect your personal data, we cannot guarantee the security of the information that we collect and store.
We retain data as required or permitted by law. For example, as a regulated financial institution, we may retain identification for 5 years or more after an account has been closed or become dormant.
How We Share Personal Information
We may disclose the information we gather with our affiliates and third parties. For example, we may share information in the following ways:
- Other AFIPAY entities, including to help detect and prevent potentially illegal acts and violations of our policies, and to guide decisions about our products, services and communications;
- Service providers who help with our business operations and to deliver our Services, such as cloud service providers providing cloud infrastructure; providers of ID verification solutions and other due diligence solutions; providers of customer service solutions; providers of website analytics; and providers of marketing automation platforms;
- Law enforcement, government officials, regulatory agencies, our banks, and other third parties pursuant to a subpoena, court order or other legal process or requirement if applicable to BitPay; to establish, exercise, or defend our or a third party’s legal rights; or when we believe, in our sole discretion, that the disclosure of information is necessary to report suspected illegal or fraudulent activity or to investigate violations of our Terms of Use;
- With another person or entity as part of any business or asset sale, equity transaction, merger, acquisition, bankruptcy, liquidation, or similar proceeding, or in preparation for any of these events;
- We may share certain Shopper information with our Merchants, for example, in cases of suspected fraud or in connection with an ongoing investigation.
- With another person or entity where you consent to the disclosure;
- For any other purpose disclosed by us when you provide the personal data or for any other purpose that we deem necessary.
Please note that these third parties may be in other countries where the laws on processing information may be less stringent than in your country. Transfer of EU data may be subject to additional legal protections we have put in place. For more information, please see the "How we share personal data with third parties and transfers outside the EEA" section of our EU Privacy Notice.
Notice at Collection Personal Information
We currently collect and, in the 12 months prior to the Last Updated Data of this Privacy Policy, have collected the following categories of California Personal Information:
- Identifiers (real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, social security number, driver’s license number, passport number, or other similar identifiers)
- Information under the California Customer Records Statute (Information that identifies, relates to, describes, or is capable of being associated with, a particular individual, including, but not limited to, his or her name, social security number, address, telephone number, passport number, driver’s license or state identification card number, bank account number, credit card number, debit card number, or any other financial information)
- Commercial Information (Records of products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies on our site)
- Internet or other similar network activity (Internet or other electronic network activity information, including, but not limited to, browsing history, search history, and information regarding a consumer’s interaction with an Internet website, application, or advertisement)
- Geolocation data
- Professional or employment-related information (Current or past job history or performance evaluations)
- Inferences drawn from other personal information (Inferences drawn from any of the information identified in this subdivision to create a profile about a consumer reflecting the consumer’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes)
For each of these categories, we obtain California Personal Information from a variety of sources. These sources include: yourself, with respect to both online and offline interactions you may have with us or our service providers; other entities with whom you transact; others with whom you maintain relationships who may deal with us on your behalf; the devices you use to access our Sites, mobile applications, and online services; identity verification and fraud prevention services; marketing and analytics providers; public databases; social media platforms; and others consistent with this section. For more information, please see the “Why We Collect Personal Information” section of our Privacy Notice.
Retention of Personal Information
We retain your Personal Information for as long as necessary to fulfill the purposes for which we collect it, such as to provide you with the service you have requested, and for the purpose of satisfying any legal, accounting, contractual, or reporting requirements that apply to us.