Privacy Policy

 

NFTIPAY

PRIVACY POLICY

 

NFTipay Brazil Ltda. (“Liberpay,” “we,” “us,” “our,” or derivative terms) is committed to respecting your privacy. This Privacy Policy explains our practices regarding the collection, use, and disclosure of information that you (“User,” “Users,” “you,” “your,” or derivative terms) may provide to us through your use of the mobile-enabled website hosted at the domain https://nftipay.com (the “Site”) and its subdomains. The platform we provide through the Site (the “Platform”) and any related services, applications, APIs, and related social media pages (the Site and the Platform, together with any services, applications, APIs, social media pages, and any other related products or services provided by Liberpay that refer to this Privacy Policy, are collectively referred to as our “Services”).

 

This Privacy Policy is incorporated into and is an integral part of our Terms of Service available at NFTIPAY.COM/TERMSOFSERVICE, which govern your access to and use of the Services. If you have entered into a separate agreement with us, that separate agreement shall prevail, and only those terms of this Privacy Policy that do not conflict with that separate agreement shall apply. This Privacy Policy does not cover third-party products and services. If you have any questions about this Privacy Policy, please contact our Data Protection Officer (DPO), Steven Albrechtsen, at PRIVACY@NFTIPAY.COM.

 

By accessing, registering for, or using the Services, you represent that you have read and acknowledge the provisions of this Privacy Policy. If you do not agree to the terms of this Privacy Policy, do not use the Services. The current version of this Privacy Policy will apply whenever you use the Services.

 

Information We Collect and How It Is Used

We collect various types of information from Users of our Services, such as: “Personal Information,” which is information you provide and that can be used to identify you (such as your name or email address).

 

INFORMATION YOU PROVIDE TO US

We collect Personal Information and other information that you voluntarily provide to us when you use our Services. Examples include:

  • Identity information, such as first and last name, photo ID, and selfies;
  • Biometric data, collected from your photo ID and selfies during our online identity verification process;
  • Contact information, such as your mailing address, email address, and phone number;
  • Feedback and correspondence, such as information you share when participating in market research activities, requesting and receiving customer support, or otherwise communicating with us;
  • Transactional data, such as the details of a purchase you make through the Services;
  • Marketing information, such as your preferences for receiving marketing communications;
  • Technical information, such as credentials, your wallet address, application programming interface (“API”) keys, and network information related to Transactions.

 

ACCOUNTS & IDENTITY VERIFICATION

When you create an account with us, Liberpay, or third-party service providers acting on behalf of Liberpay, may collect certain Personal Information about you in order to verify your identity and eligibility to use the Services and to send you login codes and other registration information regarding the Services. The data requested depends on the type of account you are requesting:

  • For a Buyer Account, you must provide your name, email address, and date of birth;
  • For a Seller Account held by an individual or a sole proprietorship, you must provide your name, email address, physical address, date of birth, and tax ID or Social Security number;
  • For a Seller Account in the name of a business or any other type of business entity, you must provide your name, email address, tax ID number, and corporate information that is not considered personal data (such as the company name, business address, the company’s tax ID number, and proof of the company’s existence).

 

In addition to the identification information required above, all Users who use the Services for Transactions involving digital currencies must provide our third-party authentication partner with a valid government-issued identity document and a facial identification scan, which will include the Users’ biometric data, in accordance with Liberpay’s identity verification procedures. In certain jurisdictions, it may be necessary to collect additional information or documents from Users for identity confirmation, as determined by Liberpay and its service providers, which we will do to the extent permitted by applicable law.

 

TRANSACTIONAL DATA

Users of our Services will conduct transactions with one another using the Platform (“Transactions”). Liberpay will collect data related to these Transactions (“Transactional Data”) and associate it with the Personal Information of the Users involved in the Transaction in order to provide the Services and facilitate the Transactions and Token Issuance Services (if applicable), in accordance with the Terms of Service. Due to the nature of blockchain applications, your wallet address and the amount of funds transferred in a digital currency Transaction will remain publicly available on the corresponding blockchain.

 

FIAT Bridge and Bridge Apps

Users may link their accounts to any third-party payment processing application integrated with our Services (individually, a “Bridge App”) to facilitate payments and invoicing for Transactions using fiat currencies (the “FIAT Bridge”). The FIAT Bridge allows Seller Accounts to accept any type of fiat currency payment from Buyer Accounts. When using the FIAT Bridge, your credit or debit card information is never shared with us, and at no point during any Transaction do we have access to that information. You shall refer to the privacy policies of the Bridge Apps to obtain additional information on how each one processes credit and debit card transactions involving fiat currencies.

 

PAYMENT INFORMATION

Any network gas charges owed to Liberpay are paid by Users, through the Bridge Apps or a digital wallet connected to the Payment Gateway, to a digital wallet maintained by Liberpay. Please note that Liberpay does not collect your credit or debit card information at any time, and we ask Users not to share this information with us when using the Services.

 

YOUR COMMUNICATION WITH US

We collect information whenever you communicate with us. The specific types of information we collect will depend on the channel through which you communicate with us. For example, when you send us an email, we will collect your email address and the content of your message.

 

MARKETING

If you subscribe to our mailing list, we or a third-party provider will collect the information you submit, and you may receive marketing and other communications from us.

 

If you do not wish to receive these types of communications, you may opt out by following the instructions included in each communication.

 

SOCIAL MEDIA

If you interact with us on social media, we may collect information from your profile, your communications with us, as well as your communications and posts on our social media pages.

 

INFORMATION WE COLLECT AUTOMATICALLY

Whenever you use our Services, we automatically receive and collect information from your device. This information includes:

  • Information about your device, such as operating system, hardware, system version, Internet Protocol (IP) address, device ID, and device language.
  • Your country and general location, time zone, and language used.
  • The specific actions you take while using our Services, including, without limitation, the pages and screens you view or visit, the search terms you enter, and how you interact with our Services.
  • The time, frequency, type of connection used, and duration of use of our Services.
  • Information related to your interaction with email messages, for example, whether you opened, clicked on, or forwarded the email message.
  • Identifiers associated with cookies or other technologies that can uniquely identify your device or browser (as described below).
  • Pages you visited before or after browsing our Services.

 

We also store information we collect through cookies, log files, clear gifs, and/or third-party sources and analytics to create a “profile” of your preferences. We may link your Personal Information to your profile information or other data sources we have about you in order to enhance the content and features of the Services for you. We do not share your profile with third parties, except for service providers we use to support our business and provide the Services to you.

 

COOKIES AND ANALYTICS

Like most sites, our Services may use “cookies” or “third-party cookies” when third parties provide services or features through our Website or Platform. Cookies are alphanumeric identifiers that we transfer to your computer’s hard drive via your web browser to help us identify you when you access our Services.

 

Our Services collect cookies and may use them for reasons that include, but are not limited to, the following:

  • To analyze our web traffic using an analytics suite.
  • To verify whether you are logged in to the Services.
  • To test content on the Services.
  • To store information about your preferences.
  • To recognize when you return to the Services.

 

In general, cookies help us provide better Services by allowing us to monitor which pages are useful to you and which are not. A cookie does not give us access to your computer in any way.

 

You can choose to accept or decline cookies. Most web browsers automatically accept cookies, but you can usually change your browser settings to decline cookies if you prefer. Doing so may prevent you from making full use of the Services.

We may use third parties, such as Google Analytics or other analytics providers, to analyze traffic on our Site. Google Analytics does not create individual profiles for visitors; it collects only aggregate data.

 

To opt out of Google Analytics, download the Google Analytics opt-out browser add-on provided by Google at http://tools.google.com/dlpage/gaoptout?hl=en.

 

To learn more about privacy and Google Analytics, refer to the Google Analytics overview provided by Google at http://www.google.com/intl/en/analytics/privacyoverview.html. You can access additional information about Google Analytics at http://www.google.com/policies/privacy/partners/. You can opt out of Google’s use of cookies by changing your settings in Google Ads Settings through Google’s ads opt-out page at http://www.google.com/policies.

 

Likewise, we may use cookies, pixels, beacons, or other web tracking technologies to monitor the time spent on our Site, Platform, or social media, as well as to verify whether certain content has been viewed or not. We may rely on third parties to collect and process this information on our behalf, based on our instructions and in accordance with this Privacy Policy.

 

Although we do our best to respect our visitors’ privacy preferences, we may not be able to respond to “Do Not Track” signals sent by your browser.

 

HOW WE USE YOUR INFORMATION

In general, we collect Personal Information about you so that we can provide our Services, operate our business, communicate with you, and provide you with the information you request from us. This includes, but is not limited to:

  • Provide, operate, improve, maintain, modify, and protect our Services.
  • Create your account and complete all identity verification procedures in accordance with our Know Your Customer (KYC), Know Your Business (KYB), and Anti-Money Laundering (AML) rules, and to allow you to use our Services and any Bridge Apps integrated with the Services.
  • Provide you with technical and other types of support.
  • Fulfill your order and deliver your products.
  • Assist you in selecting products and make product recommendations.
  • Send you updates, marketing communications, and other information about Liberpay, our Services, our products, events, promotions, and our sites.
  • Send you notices and alerts.
  • Conduct research and analysis, as well as monitor and analyze trends and usage patterns, including the performance of marketing campaigns.
  • Improve and develop our products.
  • Contact you and respond to your questions and requests and, when necessary, verify your status and identity in connection with our interactions.
  • Detect, prevent, or otherwise resolve technical, security, or fraud-related issues.
  • Enhance or improve the user experience, our business, our products, and our sites, including their security and protection.
  • Personalize our Services for you.
  • As necessary, comply with any applicable law, regulation, subpoena, legal process, or government request.
  • Enforce contracts and our Terms of Service, including investigating potential violations.
  • Protect the rights, property, or safety of Liberpay, our users, or the public from harm, as required or permitted by law.

 

How We Share Your Information

We do not sell or trade your Personal Information.

Like most companies, we share information, including Personal Information, under certain circumstances with third parties through the operation of our Services and our business. Below, we explain when this occurs.

 

TRANSACTIONS

To complete and document Transactions using our Platform, Liberpay provides a non-fungible token (“NFT”) to each User involved in a Transaction, granting the User access to certain Transactional Data and Personal Data applicable to the Transaction, including, but not limited to:

  • The buyer’s contact information (such as their name, address, email, and phone number);
  • The seller’s contact information;
  • Products/services traded; and
  • Publicly available blockchain data (as described in the “Transactional Data & Digital Wallets” section above).

 

Only the original parties to the Transaction will receive the NFT to access the Transactional Data described above. By using the Token Issuance Services in connection with a Transaction, Users consent to Liberpay sharing their Personal Information and the applicable Transactional Data with each party to the Transaction, as reasonably necessary for the completion and documentation of the Transaction.

 

SERVICE PROVIDERS

We may transfer Personal Information to third parties for the purpose of providing the Services or operating our business. For example, we may transfer your Personal Information to third-party vendors and service providers to verify your identity during the account creation process, to support the provision and improvement of the Services, to operate the FIAT Bridge, and to communicate with you regarding current or future offers.

 

NECESSARY TRANSFERS

We may also transfer your Personal Information to third parties, without prior notice to you, under the following circumstances: (i) to our affiliates and subsidiaries, (ii) to government authorities in response to government requests, (iii) to comply with a legal requirement, law, subpoena, judicial proceeding, court order, or legal process, (iv) to investigate a possible crime, such as fraud or identity theft, (v) in connection with the sale, purchase, merger, asset sale, financing, restructuring, liquidation, or dissolution of Liberpay or an affiliate, (vi) whenever we deem it necessary to protect the rights, property, or safety of Liberpay or others, or (vii) as required or permitted by law, including in connection with any of Liberpay’s contractual obligations.

 

AS DIRECTED BY YOU AND WITH YOUR CONSENT

Except as otherwise provided in this Privacy Policy, we share Personal Information with companies, organizations, or individuals outside Liberpay only according to your instructions or when we have your consent to do so.

 

THIRD-PARTY SITES

Our Services may contain hyperlinks to sites operated by third parties, which may include social media features such as social media buttons or links. We provide these hyperlinks solely for your reference and convenience. We do not control these sites and are not responsible for their content, nor for the privacy or other practices of these sites. It is your responsibility to read and fully understand the privacy policies of these sites. Liberpay’s inclusion of hyperlinks to these sites does not imply any endorsement of the material contained on these sites or any association with their operators. If you are submitting information to these third parties through our Services, you must review and understand the applicable policies of these third parties, including their privacy policies, before providing them with your information.

 

Children’s Privacy

Our Services are not intended for use by individuals under 13 years of age (or the age of legal majority in your place of residence, if that jurisdiction establishes a higher age) and we do not intentionally collect Personal Information from children under 13 years of age (or the corresponding age limit in other jurisdictions) in connection with the Services.  

 

Privacy Options and Access to Information

Platform Users may access and delete information through their account settings.

 

Depending on your jurisdiction, you may have the right to exercise certain rights regarding your Personal Information.

 

If you are a Brazilian user, you have the following rights, which may be exercised by sending an email to PRIVACY@NFTIPAY.COM:

 

  • To obtain confirmation that we are processing your Personal Information. In response to this request, we will inform you whether or not we are processing your Personal Information.

 

  • To access your Personal Information. If you wish, you may receive a report containing your Personal Information that is being processed by Liberpay.

 

  • To request the correction of Personal Information that is incomplete, inaccurate, or out of date. If you believe your Personal Information is incorrect, you may request a correction by indicating what needs to be changed and the reason for the change. We may request proof to make the necessary update.

 

  • To request the anonymization, blocking, or erasure of Personal Information that is unnecessary, excessive, or processed in violation of Brazilian law. If you believe that your Personal Information is being processed in an unnecessary, excessive, or unlawful manner under Brazilian law, you may request that such Personal Information be anonymized, blocked, or erased.

 

  • To request the portability of your Personal Information to another service or product provider, subject to our trade and industrial secrets, following regulations by the competent authority. You are the data subject of your own Personal Information. Therefore, you may request that this Personal Information be transferred to another service or product provider, in accordance with applicable regulations, provided that trade and industrial secrets are respected.

 

  • To obtain information about the sharing of your Personal Information. You may request information about the entities with which we share your Personal Information.

 

  • To obtain information about the possibility of withholding your consent and the respective consequences. When consent is used as the legal basis for the processing of Personal Information, you have the right to be informed about the possibility of withholding consent and the consequences of doing so.

 

  • To withdraw your consent to the processing of your Personal Information. If your Personal Information is processed based on consent, you may withdraw that consent. As a result, any processing of your Personal Information that is currently being carried out based on consent will be discontinued.

 

  • To object to processing that violates the law. If you believe that we are processing your Personal Information in a manner that violates the law, you may object to such processing activity. Your request will be carefully reviewed, and if we deem it appropriate, the processing of your Personal Information in violation of the law will be discontinued.

 

  • To request a review of decisions made solely based on the automated processing of your Personal Information. Decisions may be made based on the automated processing of your Personal Information. If this occurs, you may request a review of such decisions.

 

CROSS-BORDER TRANSFER

Our Services are hosted in various countries, including the United States. If you use our Services from the United Kingdom, the European Union, or other regions of the world where the laws governing the collection of data and its use may differ from those in effect in the United States and other countries, please be aware that by sending us emails or other communications containing Personal Information, or by providing Personal Information through our Services, you are voluntarily transferring your Personal Information to locations outside those regions—that is, to the United States and other countries.

 

How We Protect Your Information

We take the security of your Personal Information very seriously. We have implemented reasonable administrative, physical, and technical measures to protect the Personal Information you share with us. Despite the safeguards we have in place and our additional efforts to protect your information, we cannot promise or guarantee that hackers, cybercriminals, or unauthorized third parties will not be able to circumvent our security systems and improperly collect, access, steal, or modify your Personal Information.

 

Changes to Our Privacy Policy

We reserve the right to change this policy at any time without prior notice to Users. Whenever you use our Services, the current version of this Privacy Policy will apply. When using our Services, you must check the date of this Privacy Policy (which appears at the top of this Privacy Policy) and review any changes made since the last version.

 

Questions

If you have any questions about this Privacy Policy or our privacy practices, please contact us:

 

By email: PRIVACY@NFTIPAY.COM

By mail: 3 Howard Munroe Pl., Lexington, MA 02420

 

Notice to Residents of the European Economic Area, Switzerland, and the United Kingdom

Residents of the European Economic Area (EEA), Switzerland, and the United Kingdom have additional privacy rights. Information about these rights is available in our supplemental Privacy Notice for Residents of the European Economic Area, Switzerland, and the United Kingdom, as described below.

 

This Privacy Notice for Residents of the European Economic Area (EEA), Switzerland, and the United Kingdom supplements the information contained in our Privacy Policy and applies to residents of the EEA, the United Kingdom, and Switzerland. It contains additional information required by the EU General Data Protection Regulation (“GDPR”) and the equivalent regulations of the United Kingdom and Switzerland. These provisions, which should be read jointly with the terms of the main Privacy Policy, describe our data privacy practices in the EEA, the United Kingdom, and Switzerland.

Data controller name and contact information: Data controller name and contact information: NFTipay Inc. 3 Howard Munroe Pl. Lexington, MA 02420 United States, Phone:
Purposes of processing The purposes of processing are described in the section of the main Privacy Policy titled “Information We Collect and How It Is Used.”.
Legal Basis for Processing Our legal basis for the processing of personal data is described in the main Privacy Policy and will depend on the personal data involved and the specific context in which it is collected. In general, we engage in the processing of personal data whenever necessary to pursue our legitimate interest in conducting our business in accordance with common practices in the U.S. technology sector, taking into account any risks to your fundamental rights and freedoms (including your right to privacy). The processing of personal data may also be carried out based on other legal bases provided for in the GDPR, the UK Data Protection Act 2018, and other applicable laws, such as, for example, to fulfill a contract entered into with you or to comply with our legal obligations.
Legitimate interests of the controller or of third parties, where applicable Our specific legitimate interests, such as responding to your requests, comments, and questions; providing you with support and improving the Services; providing you with the Services; completing your transactions; and verifying your status and identity, are described in the section of the main Privacy Policy titled "Information We Collect and How It Is Used.".
Categories of personal data involved The categories of personal data we process are described in the section of the main Privacy Policy titled "Information We Collect and How It Is Used"..
Recipients or categories of recipients of personal data Recipients or categories of recipients of personal data "How We Share Your Information"..
Information on transfers of personal data to locations outside the EEA, Switzerland, and the United Kingdom NFTipay Inc. is headquartered in the U.S., and the Services are hosted in the U.S. According to the European Commission, the United Kingdom, and Switzerland, U.S. laws do not provide an adequate level of protection for personal data. When you provide us with your personal data through the Services or contact us by email, you are providing your personal data directly to the U.S. Before you provide us with your personal data through the Services, we ask for your express consent to the transfer of your personal data to the U.S. When you send us an email, the fact that you have chosen to send us an email knowing that we are located in the U.S. will be understood as your express consent to the transfer of the personal data contained in your email (including your email address) to the U.S. Regardless of any differences between U.S. and European privacy laws, we protect your personal data as described in our main Privacy Policy and in this section. If we transfer your personal data to a third party, we will require that third party to contractually commit to processing your personal data only in a manner consistent with our main Privacy Policy and this supplemental notice.
Personal data retention period or retention criteria The period for which we retain personal data varies depending on the type of data involved, the purpose for which it is used, and applicable data retention and record-keeping requirements. We erase personal data within a reasonable period after it is no longer necessary for the purpose for which it was collected or for any subsequent purpose that is compatible with the original purpose. This does not affect your right to request the erasure of your personal data before the end of the retention period. We may archive personal data (which means storing it in inactive files) for a certain period before its final erasure, as part of our normal business continuity procedures.
Your rights to access, correct, restrict, or erase your personal data and to object to the processing of your personal data You have the right to request access to your personal data, its correction, restriction, or erasure; the right to request its portability; and the right to object to the processing of your personal data. Your rights may be subject to various restrictions under the GDPR. If you wish to exercise any of these rights or if you have any questions regarding the processing of your personal data, please contact us by sending an email to PRIVACY@NFTIPAY.COM
Right to lodge a complaint with a supervisory authority You have the right to lodge a complaint concerning Liberpay’s processing of your personal data with your national (or, in some countries, regional) data protection authority. The EU Commission provides a list at https://ec.europa.eu/justice/article-29/structure/data-protection-authorities/index_en.htm. Acesse www.ico.org.uk para obter informações sobre como entrar em contato com o Gabinete do Comissário de Informações do Reino Unido (UK Information Commissioner's Office). Acesse https://ec.europa.eu/justice/article-29/structure/data-protection-authorities/index_en.htm Visit www.ico.org.uk for information on how to contact the UK Information Commissioner’s Office. Visit www.edoeb.admin.ch/edoeb/en/home.html for information on how to contact the Swiss Federal Data Protection and Information Commissioner.

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