Privacy Policy — Vaulta Pay

VaultaPay Privacy Policy

1. Introduction

VaultaPay Solutions FZC LLC ("VaultaPay", "we", "our", or "us") respects your privacy and is committed to protecting your personal information.

This Privacy Policy explains how we collect, use, disclose, store and protect your personal data when you use:

the VaultaPay website;
our customer portal;
our mobile applications (when available);
customer support services;
onboarding services;
payment and digital asset services made available through the VaultaPay platform.

This Privacy Policy should be read together with our:

Terms & Conditions
Cookie Policy
AML & KYC Notice
Risk Disclosure

By using our Services, you acknowledge that your personal information will be processed as described in this Privacy Policy.

2. Who We Are

VaultaPay Solutions FZC LLC

Floor 26
Amber Gem Tower
Sheikh Khalifa Street
Ajman
United Arab Emirates

Support Email:

support@vaulta-pay.com

VaultaPay provides access to payment and digital asset services through the financial infrastructure of Swiss Fiat AG.

Certain regulated financial services are performed by Swiss Fiat AG and its authorised service providers.

3. Scope of this Policy

This Privacy Policy applies to:

website visitors;
prospective customers;
individual customers;
business customers;
authorised users;
company directors;
shareholders;
beneficial owners;
employees acting on behalf of business customers;
individuals contacting customer support.

It also applies to information collected during:

onboarding;
identity verification;
payment processing;
customer support;
fraud prevention;
compliance monitoring.

4. Information We Collect

Depending on the Services you use, we may collect the following categories of information.

Personal Information

This may include:

full name;
date of birth;
nationality;
residential address;
email address;
telephone number;
government-issued identification details;
passport information;
driver's licence information;
national identity card details.

Business Information

Where you represent a business, we may collect:

company name;
registered address;
company registration number;
tax identification numbers;
names of directors;
names of shareholders;
Ultimate Beneficial Owner (UBO) information;
business activity information;
expected transaction volumes.

Financial Information

Where relevant, we may collect:

bank account details;
IBAN information;
payment instructions;
payment references;
account balances;
transaction history;
currency exchange information;
digital asset wallet addresses;
blockchain transaction references.

Identity Verification Information

To comply with legal and compliance obligations, we may collect:

photographs of identity documents;
proof of address;
selfie verification;
biometric verification where applicable;
source of funds documentation;
source of wealth documentation;
sanctions screening results;
politically exposed person (PEP) screening information.

Technical Information

When you use our website or platform we may automatically collect:

IP address;
browser type;
operating system;
device identifiers;
login timestamps;
session information;
security logs;
usage statistics;
error reports.

Communications

We may retain records of communications including:

emails;
live chat;
customer support tickets;
telephone conversations where legally permitted;
complaints;
feedback.

5. Information We Receive From Third Parties

We may receive information from:

identity verification providers;
sanctions screening providers;
fraud prevention providers;
payment service providers;
blockchain analytics providers;
banking partners;
publicly available corporate registers;
law enforcement authorities where legally authorised.

6. How We Collect Information

Information may be collected:

directly from you;
during onboarding;
through website forms;
during customer support interactions;
through payment transactions;
from identity verification providers;
through cookies and similar technologies;
from publicly available sources where legally permitted.

7. Why We Process Your Information

We process personal information only where there is an appropriate legal basis.

These purposes include:

Providing the Services

To:

create your account;
verify your identity;
provide payment services;
provide account functionality;
process transactions;
administer your relationship with VaultaPay.

Compliance

To comply with:

anti-money laundering obligations;
counter-terrorist financing obligations;
sanctions screening requirements;
fraud prevention obligations;
legal reporting obligations;
court orders;
regulatory requests where applicable.

Customer Support

To:

respond to enquiries;
investigate issues;
improve customer experience;
resolve complaints.

Security

To:

detect fraud;
protect customer accounts;
investigate suspicious activity;
monitor platform security;
prevent unauthorised access.

Improving Our Services

We may analyse information to:

improve our products;
enhance security;
understand platform performance;
develop new features;
improve customer support.

Where possible, this analysis will use aggregated or anonymised information.

8. Lawful Basis for Processing

Where applicable under data protection laws, we process personal data on one or more of the following legal bases:

performance of a contract;
compliance with legal obligations;
legitimate business interests;
protection against fraud;
establishment or defence of legal claims;
consent, where required by law.

Where processing is based upon consent, you may withdraw your consent at any time, although this will not affect processing already undertaken.

9. Sharing Your Information

We do not sell your personal information.

We may share information only where necessary with:

Swiss Fiat AG;
identity verification providers;
payment service providers;
banking partners;
digital asset infrastructure providers;
fraud prevention providers;
sanctions screening providers;
cloud hosting providers;
technology providers;
professional advisers;
auditors;
legal advisers;
competent authorities where legally required.

All third parties receiving personal information are expected to protect that information appropriately and only process it for authorised purposes.

10. International Transfers

Because VaultaPay operates internationally, your personal information may be transferred between countries where necessary to provide the Services.

Such transfers may include jurisdictions in which VaultaPay, Swiss Fiat AG or authorised service providers operate.

Where required by applicable law, appropriate safeguards will be implemented to protect personal information during international transfers.

VaultaPay Privacy Policy (Part 2 – Final)

11. Data Retention

VaultaPay retains personal information only for as long as necessary to:

provide the Services;
comply with legal and regulatory obligations;
resolve disputes;
enforce our agreements;
prevent fraud and financial crime;
maintain appropriate business records.

Retention periods depend upon the nature of the information and applicable legal requirements.

When personal information is no longer required, it will be securely deleted, anonymised or otherwise disposed of using appropriate technical and organisational measures.

12. Your Rights

Depending on your location and the applicable data protection laws, you may have the right to:

request access to your personal information;
request correction of inaccurate or incomplete information;
request deletion of personal information where legally permitted;
request restriction of processing;
object to certain processing activities;
request portability of your personal information in a structured, commonly used and machine-readable format where applicable;
withdraw consent where processing is based on consent;
lodge a complaint with a competent data protection authority where applicable.

These rights are not absolute and may be subject to legal or regulatory obligations, including obligations relating to anti-money laundering, fraud prevention and record retention.

Requests should be sent to support@vaulta-pay.com. We may ask you to verify your identity before responding to your request.

13. Cookies and Similar Technologies

VaultaPay uses cookies and similar technologies to:

ensure the website functions correctly;
remember your preferences;
improve website performance;
analyse website usage;
maintain security;
support fraud prevention measures.

Further information about our use of cookies is available in our Cookie Policy.

14. Marketing Communications

Where permitted by law, VaultaPay may send you information about:

product updates;
service announcements;
platform improvements;
educational content;
promotional communications relating to our Services.

You may opt out of receiving marketing communications at any time by using the unsubscribe link included in the communication or by contacting us directly.

We will continue to send important service-related communications where necessary for the operation of your account.

15. Automated Decision-Making

Certain processes may involve automated systems designed to support:

fraud detection;
sanctions screening;
identity verification;
transaction monitoring;
cybersecurity;
compliance assessments.

Where required by applicable law, you may request additional information about decisions that have a legal or similarly significant effect on you and, where appropriate, request a review by a suitably authorised member of our team.

16. Data Security

VaultaPay implements appropriate technical and organisational measures designed to protect personal information against:

unauthorised access;
accidental loss;
destruction;
alteration;
misuse;
unlawful disclosure.

Security measures may include:

encryption of data in transit using industry-standard protocols;
encryption of sensitive data at rest where appropriate;
role-based access controls;
multi-factor authentication for administrative access where applicable;
continuous security monitoring;
logging and audit trails;
vulnerability assessments and security testing.

While we strive to protect your personal information, no method of transmission over the internet or electronic storage can be guaranteed to be completely secure.

17. Data Breaches

If VaultaPay becomes aware of a personal data breach that is likely to result in a risk to individuals' rights and freedoms, we will take appropriate steps in accordance with applicable law.

These steps may include:

investigating the incident;
containing and mitigating the impact;
notifying affected individuals where required;
notifying relevant authorities where legally required;
implementing corrective measures to reduce the likelihood of recurrence.

18. Third-Party Websites

Our website or communications may contain links to third-party websites or services.

VaultaPay is not responsible for the privacy practices, security measures or content of third-party websites.

Users are encouraged to review the privacy policies of any third-party websites they visit.

19. Children's Privacy

The Services are intended for individuals who are at least eighteen (18) years of age.

VaultaPay does not knowingly collect personal information from children.

If we become aware that personal information relating to a child has been collected without appropriate authorisation, we will take reasonable steps to delete that information.

20. Changes to this Privacy Policy

VaultaPay may update this Privacy Policy from time to time to reflect changes in:

legal requirements;
regulatory obligations;
technology;
our Services;
our business practices.

The latest version of the Privacy Policy will be published on our website with the updated effective date.

Where required by law, we will provide appropriate notice of material changes.

21. Contact Us

If you have questions about this Privacy Policy or how your personal information is processed, please contact:

VaultaPay Solutions FZC LLC

Floor 26
Amber Gem Tower
Sheikh Khalifa Street
Ajman
United Arab Emirates

Email: support@vaulta-pay.com

We will make reasonable efforts to respond to privacy-related enquiries in a timely manner.

22. Regulatory Information

VaultaPay operates through the financial infrastructure of Swiss Fiat AG.

Swiss Fiat AG is incorporated in Switzerland with its registered office at Alpenstrasse 1, 6004 Lucerne, Switzerland, and is registered under company number CHE-311.324.141.

Swiss Fiat AG is affiliated with SO-FIT – Organisme de Surveillance pour Intermédiaires Financiers & Trustees (Affiliation No. 1524) as a financial intermediary in accordance with the Swiss Anti-Money Laundering Act (AMLA). SO-FIT is a self-regulatory organisation recognised by the Swiss Financial Market Supervisory Authority (FINMA).