1. Introduction
Thank you for choosing exSat Pay, its affiliates, successors, assigns, and subsidiaries (hereinafter “we,” “us,” or “our”). This Privacy Policy explains how we collect, use, disclose, and protect your personal data when you use our payment services, digital wallets, and related financial products (collectively, “Services”). By accessing or using our Services, you represent that you have read and consent to the practices described herein. If you do not agree, please notify us in writing, close your exSat Pay account, delete any cookies you may have on your devices, and cease all use of the Services.
This Privacy Policy applies to the exSat Pay website at https://www. exsat.cards (including any subdomains or mobile applications of such sites) (the “Sites”) or use of any Services (as defined in the exSat Pay Terms and Conditions). Any capitalized terms not defined herein will have the meaning assigned to them in the General Terms and Conditions or accompanying agreements. This Privacy Policy does not apply to any other website operated by any third party.
We may update this policy periodically. Continued use after changes constitutes acceptance.
2. Personal Data We Collect
We collect data necessary to provide our Services, including but not limited to:
Identity Verification: Full name, ID/passport details, date of birth, nationality.
Contact Details: Address, email, phone number.
Financial Information: Bank account details, transaction history, credit data, blockchain addresses.
Technical Data: IP address, device information, cookies (see Section 9).
Compliance Data: Source of funds, occupation, KYC/AML documentation.
Sensitive Data: We may process biometric data (e.g., for authentication) only with explicit consent.
3. How We Use Your Data
Your data is used for:
Service Delivery: Account setup, transaction processing, fraud prevention.
Legal Compliance: AML/CFT checks, tax reporting, regulatory obligations.
Improvement: Analytics, product development, customer support.
Marketing: Promotions (only with your opt-in consent; see Section 8).
4. Data Sharing & Disclosure
We may share data with:
Group Companies & Service Providers: Banks, payment processors, KYC vendors.
Regulators & Authorities: As required by British Virgin Islands law.
Credit Reference Agencies: For credit assessments under the Multiple Credit Reference Agencies Model.
Business Transferees: In mergers/acquisitions.
No sale of personal data to third parties for unrelated marketing.
5. International Data Transfers
Data may be transferred outside British Virgin Islands (e.g., cloud servers, global partners). We ensure safeguards (e.g., encryption, contracts) align with Data Protection Act, 2021 (DPA) requirements.
6. Data Retention
We retain data only as long as necessary:
Active Accounts: For service provision.
Legal Requirements: Up to 7 years for AML/tax records.
Credit Data: Per Code of Practice on Consumer Credit Data (e.g., 5 years post-account closure).
7. Your Rights
Under the DPA, you may:
Access/Correct your data.
Withdraw Consent (e.g., for marketing).
Request Deletion (subject to legal limits).
Opt Out of Credit Data Sharing (contact us within 5 years of account closure).
Requests: Email [privacy@ exSatpay.com] with proof of identity.
8. Direct Marketing
We may use your data (name, transaction history) to market:
Financial products (e.g., credit cards, loans).
Rewards programs or co-branded offers.
Charitable initiatives.
Opt-out: Unsubscribe via email or app settings.
9. Cookies & Tracking
We use cookies to:
Analyze website traffic (anonymous aggregates).
Enhance security (e.g., fraud detection).
Personalize user experience.
Disable cookies via browser settings, but some features may not work.
10. Security Measures
We implement:
Encryption (SSL/TLS for data transfers).
Access Controls (role-based permissions).
Regular Audits.
Note: No system is 100% secure—promptly report suspicious activity.
11. Minor Policy
Services are not offered to minors (under 18). We delete inadvertent collections of minor data upon notice.
12. Contact Us
For privacy inquiries or requests:
exSat Pay Data Protection Officer
📧 Email: [support@exsat.cards]
📞 Phone: [Customer Service Hotline]
Complaints: May be escalated to the relevant authorities.
13. Governing Language
The English version prevails over any translated versions.
By using exSat Pay, you acknowledge this policy.