Privacy Policy

Types of Data Collected

We collect only the Personal Data that is necessary to provide the Service, to keep Your Account secure, and to comply with the law. The data We collect depends on the features You use.

Personal Data

When You register for an Account, We ask You to provide Us with certain personally identifiable information that can be used to contact or identify You. This includes:

• First name and last name
• Email address
• Password (transmitted in encrypted form and used solely to authenticate You)
• Phone number and country dialling code
• Address, City, Country and ZIP/Postal code
• Date of birth

You are responsible for ensuring that the information You provide to Us is accurate, complete and kept up to date.

Identity Verification (KYC) Data

As a provider of financial services, We are required to verify the identity of Our customers.

Before You can access certain features, such as payment cards and withdrawals, We collect:

• Identity document type (for example, passport, national identity card or other government-issued identity document)
• Identity document number, date of issue and date of expiry
• Images of the front and back of Your identity document
• A photograph of You holding Your identity document, used to confirm that You are the person to whom the document was issued
• Occupation
• Annual income, the intended purpose of Your Account, and Your expected monthly transaction volume
• The status and outcome of Your Identity Verification

Financial and Transaction Data

When You use the financial features of the Service, We collect:

• Wallet data: balances and the cryptocurrency deposit addresses generated for Your Account
• Deposit and withdrawal data: amounts, currencies, blockchain networks, wallet addresses, transaction identifiers, dates and status
• Payment card data: card type, card network, card number (masked except where the full number is required for the card to function), card status, top-up history, and card transaction records including merchant names, amounts and dates. Card PIN change requests are transmitted securely to the card issuer for processing.
• Peer-to-peer (P2P) transfer data: the recipient’s CentPay identifier or email address, the amount, the network and the status of the transfer
• International transfer data: the sender and recipient details required by the payout partner (such as names, addresses, dates of birth, nationality, contact details and bank or payout details), together with the transfer type, payout currency, payout method, amount, fees and status
• Cryptocurrency service data: the currencies, amounts, provider, payment method and recipient wallet address You select when using the Buy, Sell or Swap features
• Premium membership data: the plan You select, its price and duration, and the related charges deducted from Your wallet balance
• Rewards data: referral bonus and cashback records

When You provide Personal Data about another person, such as the recipient of a transfer, You confirm that You are entitled to share it with Us for that purpose.

Account Security Data

• Two-factor authentication (2FA) configuration data
• Login activity, including the date and time of each login, Your IP address, Your device and browser type, and the approximate city and country derived from Your IP address
• Records of security events, such as password changes and 2FA verification attempts

Customer Support Data

When You contact Us, We collect the content of Your support tickets, including the title, category, priority, description and any comments, together with Our correspondence with You.

Usage Data

Usage Data is collected automatically when using the Service. When You access the Service through a mobile device, We may collect certain information automatically, including the type of mobile device You use, Your mobile operating system and version, the version of the Application, Your network connectivity status, and the IP address of Your mobile device.

We use Your IP address to determine Your approximate location at country and city level. We use this to show You only the services and Third-Party Providers that are lawfully available in Your jurisdiction, and to detect suspicious activity on Your Account.

Crash and Diagnostic Data

We use Firebase Crashlytics, a service provided by Google LLC, to detect and fix Application crashes and errors. When the Application crashes, Crashlytics collects technical information such as the error details, Device model, operating system version, an Application installation identifier, and the state of the Application at the time of the crash. Crash reports may be associated with Your CentPay user identifier and email address so that We can investigate problems affecting Your Account. This data is used only to keep the Service stable and secure, and is never used for advertising.

Information Collected while Using the Application

While using Our Application, and only with Your prior permission, We may access:

• Your Device’s camera, so that You can photograph Your identity documents and take Your verification photo
• Your Device’s photo library or storage, so that You can upload existing images of Your identity documents

We use this information only to complete Your Identity Verification. You can enable or disable access to this information at any time through Your Device settings. Disabling access may prevent You from completing Identity Verification.

Information We Do Not Collect

For transparency, the Application does not collect:

• Your precise GPS location
• Your contacts or address book
• Your Device’s advertising identifier
• Audio or recordings from Your microphone
• Your browsing activity on other websites or applications
• Health or medical information

We do not track You across applications or websites owned by other companies.

Sensitive Personal Data

Some of the data We collect, such as identity document details and images, financial account and payment card information, and login credentials, is considered sensitive under data protection laws. We process this data only where necessary for the purposes described in this Privacy Policy, and We protect it with enhanced security measures.

Where the comparison of Your verification photo with Your identity document involves biometric processing, We carry it out only where permitted by law, such as for the prevention of fraud and financial crime, or with Your explicit consent where the law requires it. We do not intentionally collect other special categories of data, such as data about health, religious beliefs or political opinions, and We ask that You do not include such information in Your communications with Us.