Pays Solutions ("Pays," "we," "us," or "our") operates the Pays Wallet mobile application and the pays.solutions website. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you use our services.

1. Information We Collect

1.1 Information You Provide

Account information — email address, name, and authentication credentials created when you sign up via social login, Apple Sign-In, or passkey.
Identity verification — government-issued identification documents, selfie photographs, date of birth, nationality, and residential address submitted during Know Your Customer (KYC) verification, which is processed by our partner SumSub.
Financial information — wallet addresses, transaction history, card spending activity, and fiat deposit and withdrawal transaction details.
Contact information — email addresses of recipients when you use the send-by-email feature, and contacts you add to your address book.
Support communications — messages, attachments, and metadata exchanged through our in-app support powered by Intercom.

1.2 Information Collected Automatically

Device information — device model, operating system version, unique device identifiers, and app version.
Usage data — features accessed, screens viewed, interaction timestamps, and performance metrics.
Network information — IP address, connection type, and general location derived from your IP address.
Blockchain data — on-chain transaction data associated with your wallet addresses on supported networks (Base, Arbitrum, Optimism, and Polygon), retrieved via Alchemy.

1.3 Information from Third Parties

Authentication providers — profile information from Privy and social login providers you use to create your account.
Card issuer — transaction data, card status, and compliance information from Gnosis Pay relating to your virtual Visa debit card.
Deposit/withdrawal provider — transaction status and compliance data from Bridge when you deposit or withdraw funds.
Price data — market data from CoinGecko used to display token prices and portfolio values.

2. How We Use Your Information

We use your information to:

Create and maintain your Pays Wallet account.
Process cryptocurrency transactions, swaps, and card payments.
Issue and manage your virtual Visa debit card through Gnosis Pay.
Verify your identity to comply with anti-money laundering (AML) and know-your-customer (KYC) regulations.
Facilitate the sending of cryptocurrency via email.
Process fiat deposit and withdrawal transactions through Bridge.
Display real-time token balances, prices, and transaction history.
Provide customer support through Intercom.
Detect, prevent, and investigate fraud or unauthorised activity.
Send transactional notifications such as card activity alerts and transfer confirmations.
Improve our services, fix bugs, and develop new features.
Comply with applicable laws, regulations, and legal processes.

3. How We Share Your Information

We do not sell your personal information. We share information only in the following circumstances:

3.1 Service Providers

We share data with third-party providers who help us operate our services:

Privy — authentication and wallet infrastructure.
ZeroDev — smart wallet and account abstraction infrastructure.
Gnosis Pay — virtual Visa card issuance, payment processing, and compliance.
SumSub — identity verification and KYC/AML compliance.
Bridge — fiat deposit and withdrawal services.
Alchemy — blockchain data indexing and transaction monitoring.
Intercom — customer support and in-app messaging.
CoinGecko — cryptocurrency market data.

3.2 Legal Requirements

We may disclose your information if required by law, regulation, legal process, or governmental request, or when we believe disclosure is necessary to protect our rights, your safety, or the safety of others.

3.3 Business Transfers

In the event of a merger, acquisition, or sale of assets, your information may be transferred as part of that transaction. We will notify you of any such change.

4. Self-Custody and Blockchain Data

Pays Wallet is a self-custody wallet. Your private keys are generated and stored on your device and are never transmitted to or stored on our servers. We cannot access, freeze, or recover your cryptocurrency holdings.

Blockchain transactions are recorded on public, decentralised networks. Transaction data — including wallet addresses, amounts, and timestamps — is publicly visible and cannot be deleted or modified by Pays or any other party. We are not responsible for the privacy implications of data recorded on public blockchains.

5. Data Security

We implement industry-standard technical and organisational measures to protect your information, including encryption in transit (TLS) and at rest, secure key storage on-device using platform-native secure enclaves, and access controls for internal systems. Despite these safeguards, no method of electronic transmission or storage is completely secure. We cannot guarantee absolute security.

6. Data Retention

We retain your personal information for as long as your account is active or as needed to provide services. We also retain data as necessary to comply with legal obligations (including AML record-keeping requirements), resolve disputes, and enforce our agreements. Identity verification records may be retained for a minimum period as required by applicable financial regulations.

7. Your Rights

Depending on your jurisdiction, you may have the right to:

Access the personal information we hold about you.
Request correction of inaccurate or incomplete information.
Request deletion of your personal information, subject to legal retention requirements.
Object to or restrict certain processing of your information.
Request portability of your data in a structured, machine-readable format.
Withdraw consent where processing is based on consent.

To exercise any of these rights, contact us at contact@pays.solutions. We will respond within 30 days, or as required by applicable law.

8. International Data Transfers

Your information may be processed in countries other than the one in which you reside. When we transfer data internationally, we ensure appropriate safeguards are in place, including standard contractual clauses or equivalent mechanisms approved by relevant data protection authorities.

9. Children's Privacy

Pays Wallet is not intended for individuals under the age of 18. We do not knowingly collect personal information from children. If we learn that we have collected information from a person under 18, we will delete it promptly.

10. Third-Party Links and Services

Our services may contain links to third-party websites or integrate with third-party services. This Privacy Policy does not apply to those third parties. We encourage you to review the privacy policies of any third-party services you access through Pays Wallet.

11. Push Notifications

With your permission, we may send push notifications for transaction alerts, card activity, security events, and service updates. You can manage notification preferences through your device settings at any time.

12. Changes to This Policy

We may update this Privacy Policy from time to time. When we make material changes, we will notify you through the app or by email. The "Effective date" at the top of this page indicates the date of the latest revision. Your continued use of Pays Wallet after changes are posted constitutes acceptance of the updated policy.

13. Contact Us

If you have questions or concerns about this Privacy Policy or our data practices, contact us at:

Email: contact@pays.solutions
In-app support:Account → Help & Support