1. Introduction

AXPay SARL (Société à responsabilité limitée), registered at Spaces/Regus, 53 Boulevard Royal, L-2449 Luxembourg (“we,” “our,” or “us”), is committed to protecting your privacy. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you use our high risk payment gateway services, including our website and payment processing platform.

By using our services, you agree to the collection and use of information in accordance with this policy. If you do not agree with our policies and practices, please do not use our services.

2. Information We Collect

• Account Information: Name, email address, company name, phone number, business address
• Business Information: Business type, industry, registration documents, tax information
• Financial Information: Bank account details, payment card information (processed securely)
• Transaction Data: Payment amounts, transaction history, customer information
• Communication Data: Emails, chat messages, support tickets

2.2 Automatically Collected Information

• Usage Data: IP address, browser type, device information, pages visited
• Cookies: Session cookies, preference cookies, analytics cookies
• Log Data: Access times, error messages, system activity

3. How We Use Your Information

We use the collected information for the following purposes:

• Provide and maintain our payment processing services
• Process transactions and prevent fraud
• Comply with legal and regulatory requirements (KYC, AML)
• Improve our services and develop new features
• Communicate with you about your account and services
• Provide customer support and respond to inquiries
• Send marketing communications (with your consent)
• Analyze usage patterns and optimize performance

4. Information Sharing and Disclosure

4.1 Service Providers

We may share your information with third-party service providers who perform services on our behalf:

• Payment processors and acquiring banks
• Fraud detection and prevention services
• Cloud hosting providers
• Customer relationship management platforms
• Analytics and monitoring services

4.2 Legal Requirements

We may disclose your information when required by law or to:

• Comply with legal obligations and regulatory requirements
• Respond to lawful requests from public authorities
• Protect our rights, privacy, safety, or property
• Investigate potential fraud or security issues

4.3 Business Transfers

If we are involved in a merger, acquisition, or sale of assets, your information may be transferred as part of that transaction.

5. Data Security

We implement appropriate technical and organizational measures to protect your information:

• Encryption: SSL/TLS encryption for data in transit, AES-256 encryption for data at rest
• Access Controls: Role-based access, multi-factor authentication
• Monitoring: 24/7 security monitoring and incident response
• Compliance: PCI DSS Level 1 certified infrastructure
• Regular Audits: Third-party security assessments and penetration testing

6. Data Retention

We retain your information for as long as necessary to:

• Provide our services to you
• Comply with legal obligations (typically 7 years for financial records)
• Resolve disputes and enforce our agreements
• Maintain fraud prevention databases

7. Your Rights

Depending on your location, you may have the following rights:

• Access: Request a copy of your personal information
• Correction: Request correction of inaccurate information
• Deletion: Request deletion of your information (subject to legal requirements)
• Portability: Request transfer of your data to another provider
• Objection: Object to processing of your information
• Withdrawal: Withdraw consent for marketing communications

To exercise these rights, please contact us at hello@axpay.net

8. International Data Transfers

We process data globally and may transfer your information to countries outside your residence. We ensure appropriate safeguards are in place, including:

• Standard Contractual Clauses (SCCs)
• Adequacy decisions by relevant authorities
• Binding Corporate Rules

9. Cookies and Tracking Technologies

We use cookies and similar technologies to:

• Maintain your session and remember your preferences
• Analyze website usage and improve our services
• Provide personalized content and advertisements

You can control cookies through your browser settings, but disabling cookies may limit functionality.

10. Children’s Privacy

Our services are not intended for individuals under 18 years of age. We do not knowingly collect personal information from children. If you believe we have collected information from a child, please contact us immediately.

11. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. We will notify you of any material changes by:

• Posting the new Privacy Policy on our website
• Updating the “Last Updated” date
• Sending an email notification (for significant changes)

12. Contact Us

If you have questions or concerns about this Privacy Policy, please contact us:

• Email: hello@axpay.net
• Address: AXPay SARL, Spaces/Regus, 53 Boulevard Royal, L-2449 Luxembourg
• Contact Form: axpay.net/contact

13. Specific Jurisdictions

13.1 GDPR (European Union)

For EU residents, we comply with the General Data Protection Regulation (GDPR). Our legal basis for processing includes contract performance, legal obligations, and legitimate interests.

13.2 CCPA (California)

California residents have additional rights under the California Consumer Privacy Act (CCPA), including the right to opt-out of the sale of personal information. We do not sell personal information.

13.3 Other Jurisdictions

We comply with applicable data protection laws in all jurisdictions where we operate.