Privacy Policy

Information We Collect

1.1 Information You Provide

We may collect information you provide directly to us, including:

• legal names;
• business names;
• addresses;
• email addresses;
• phone numbers;
• dates of birth;
• government-issued identification;
• tax identification numbers;
• beneficial ownership information;
• corporate formation documents;
• wallet addresses;
• bank account information;
• payment information;
• transaction instructions;
• support communications; and
• compliance documentation.

1.2 Transaction & Account Information

We may collect information related to:

• account activity;
• wallet activity;
• blockchain transactions;
• payout activity;
• transfer history;
• transaction counterparties;
• settlement activity;
• balances;
• IP addresses;
• device identifiers;
• login history;
• API activity;
• fraud indicators; and
• risk scoring information.

1.3 Information from Third Parties

We may collect information from:

• identity verification providers;
• blockchain analytics providers;
• sanctions screening providers;
• fraud prevention providers;
• financial institutions;
• card issuers;
• Service Providers;
• public databases;
• regulatory agencies;
• business information providers; and
• law enforcement or governmental authorities.

How We Use Information

We may use information for purposes including:

• providing and operating the Services;
• onboarding and account administration;
• identity verification;
• KYC and KYB compliance;
• sanctions screening;
• blockchain analytics;
• transaction monitoring;
• fraud prevention;
• cybersecurity;
• Travel Rule compliance;
• customer support;
• reporting and analytics;
• improving the Services;
• enforcing agreements and policies;
• regulatory compliance;
• legal investigations;
• risk management; and
• communicating with users.

Compliance Monitoring & Regulatory Disclosures

Paymenture and its Service Providers may monitor transactions, wallets, account activity, counterparties, and blockchain activity for purposes including:

• anti-money laundering compliance;
• sanctions compliance;
• fraud detection;
• cybersecurity;
• suspicious activity detection;
• Travel Rule obligations;
• operational risk management; and
• regulatory reporting.

You acknowledge and agree that Paymenture may:

• conduct sanctions screening;
• utilize blockchain analytics providers;
• review account and transaction activity;
• collect compliance-related information;
• cooperate with regulators and law enforcement;
• disclose information where required by law;
• file Suspicious Activity Reports ("SARs");
• respond to subpoenas or legal requests; and
• share information with Service Providers and compliance vendors.

Paymenture may be prohibited by law from disclosing certain investigations, monitoring activity, or reporting obligations.

How We Share Information

We may share information with:

• sponsor banks;
• payment processors;
• card issuers;
• blockchain analytics providers;
• sanctions screening providers;
• fraud prevention providers;
• VASPs;
• liquidity providers;
• identity verification providers;
• cloud service providers;
• professional advisers;
• regulators;
• law enforcement;
• auditors; and
• other third parties where reasonably necessary to provide the Services or comply with law.

We may also share information:

• in connection with mergers, acquisitions, financings, or asset sales;
• to protect the rights or security of Paymenture or others;
• to investigate fraud or suspicious activity; or
• with your consent.

Digital Asset & Blockchain Data

Blockchain transactions may be publicly visible and inherently transparent.

Paymenture may collect, analyze, retain, and share blockchain-related information including:

• wallet addresses;
• transaction hashes;
• blockchain metadata;
• transaction counterparties;
• blockchain risk scores;
• blockchain exposure data; and
• sanctions or compliance indicators.

Paymenture may utilize blockchain analytics and compliance technologies in connection with Digital Asset Services.

Cookies & Tracking Technologies

Paymenture may use:

• cookies;
• pixels;
• analytics tools;
• session tracking;
• log files;
• API monitoring tools; and
• similar technologies

to operate, secure, analyze, and improve the Services.

Users may be able to manage certain browser cookie settings, though disabling certain technologies may affect Service functionality.

Data Retention

Paymenture may retain information for as long as reasonably necessary to:

• provide the Services;
• comply with law;
• satisfy AML and sanctions obligations;
• comply with recordkeeping requirements;
• resolve disputes;
• enforce agreements;
• detect fraud; or
• protect Paymenture and its Service Providers.

Certain records may be retained for five years or longer where required by applicable law or regulatory obligations.

Data Security

Paymenture maintains administrative, technical, and organizational safeguards designed to protect information from:

• unauthorized access;
• misuse;
• alteration;
• disclosure;
• destruction; or
• cybersecurity threats.

However, no system or transmission method can be guaranteed to be completely secure.

Users are responsible for maintaining the confidentiality and security of their credentials and authorized access.

International Data Transfers

Paymenture and its Service Providers may process or transfer information internationally in connection with providing the Services.

By using the Services, you acknowledge and agree that information may be transferred to jurisdictions that may have different data protection laws than your home jurisdiction.

Your Rights & Choices

Depending on applicable law, you may have certain rights regarding your personal information, including rights to:

• access information;
• correct information;
• request deletion;
• object to certain processing;
• request portability; or
• withdraw consent where applicable.

Certain rights may be limited by:

• AML obligations;
• sanctions compliance obligations;
• legal retention requirements;
• fraud prevention requirements;
• cybersecurity obligations; or
• regulatory requirements.

Requests may be submitted to privacy@paymenture.com.

Children's Privacy

The Services are not intended for individuals under the age of 18.

Paymenture does not knowingly collect personal information from children.

Third-Party Services & Links

The Services may integrate with or link to third-party services, websites, applications, wallets, exchanges, or providers.

Paymenture is not responsible for the privacy practices or content of third-party services.

Users should review the privacy policies of third-party providers separately.

Changes to This Privacy Policy

Paymenture may modify this Privacy Policy from time to time to:

• comply with law;
• reflect operational changes;
• address new technologies;
• address regulatory developments; or
• improve transparency.

Updated versions will be posted on the Paymenture website.

Continued use of the Services constitutes acceptance of the updated Privacy Policy.