1. General Provisions

1.1. This Privacy Policy governs the collection, use, storage, transfer, and protection of personal data for users of the AnyPay service, accessible via Telegram (bot or mini app) and web interfaces.

1.2. The data controller is AnyPay, including other AnyPay group companies, unless otherwise specified.

1.3. This Policy forms an integral part of the User Agreement and is applied together with it.

1.4. If a user is located within the European Economic Area or the United Kingdom, data processing is in accordance with GDPR and UK GDPR.

2. Legal Basis for Data Processing

Your personal data is processed on one or more of these grounds: fulfillment of a contract, compliance with legal obligations, legitimate interests of the company, and where required, your consent under applicable law.

3. Data We May Process

We may process identification and contact details, document information, data required for KYC/AML/sanctions checks, transaction details, source of funds, technical data, and information on service usage.

4. Purposes of Data Processing

Personal data is used to register and service your account, provide our services, comply with legal requirements, prevent fraud, communicate with you, fulfill partner obligations, improve the service, and send notifications or marketing messages where permitted by law.

5. Data Disclosure to Third Parties

We may share data within the AnyPay group, card issuers, payment partners, KYC/AML providers, anti-fraud providers, IT contractors, and government/regulatory authorities when legally necessary. Data is shared strictly for the required purpose.

6. Cross-Border Data Transfers

Data may be transferred internationally, including outside the EEA. In such cases, we ensure your data is subject to appropriate safeguards under applicable law.

7. User Rights

You have the right to request access, rectification, deletion, restriction of processing, data portability, to withdraw consent, and to lodge a complaint with a supervisory authority. Requests may be made via customer support.

8. Data Storage and Protection

We retain data only as long as necessary for processing purposes or as required by law and implement reasonable technical and organizational safeguards.

9. Automated Decision-Making

Automated systems may be used to assess risks, analyze transactions, and prevent fraud, which may, in some cases, result in temporary restrictions or additional verification.

10. Marketing Communications

Service notifications are essential to service provision. Marketing messages are sent only as permitted by law and, where necessary, with your consent.

11. Cookies and Technical Data

We use only strictly necessary cookies unless you give additional consent. Cookie preferences can be managed via your browser or device.

12. Changes to Policy

We may update this Policy. The current version is always available via service interfaces. By continuing to use the service, you accept the revised Policy.

13. Contact

For questions regarding personal data processing: corp@any-pay.app