This Privacy Policy explains how Paioptimum OÜ (“Paioptimum”, “Company”, “we”, “us”, or “our”) collects, uses, processes, stores, transfers, and protects personal data when you use our application, website, APIs, and related services (the “Services”).

This Privacy Policy should be read together with our User Agreement and Risk Disclosure.

1. Scope

This Privacy Policy applies to personal data processed in connection with the Services.

2. Information We Collect

2.1 Information You Provide

We may collect:

• full name;
• date of birth;
• nationality;
• residential address;
• email address;
• phone number;
• government-issued identification documents;
• selfie and biometric verification materials where permitted;
• occupation and business information;
• source-of-funds or source-of-wealth information; and
• communications with us.

2.2 Account and Transaction Information

We may collect:

• wallet addresses;
• blockchain transaction records;
• conversion and OTC activity;
• device and login information;
• account settings;
• compliance review information; and
• risk-scoring and monitoring data.

2.3 Technical Information

We may collect:

• IP address;
• browser information;
• operating system information;
• cookies and device identifiers;
• access logs; and
• usage analytics.

3. How We Use Personal Data

We may use personal data to:

• provide and operate the Services;
• create and manage accounts;
• process transactions;
• conduct identity verification and compliance checks;
• detect and prevent fraud, abuse, money laundering, sanctions violations, and unauthorized activity;
• comply with legal and regulatory obligations;
• improve security and system performance;
• communicate with users;
• provide customer support; and
• send service-related notices.

4. Legal Basis for Processing

We process personal data based on one or more of the following legal bases:

• performance of a contract;
• compliance with legal obligations;
• legitimate interests;
• protection against fraud and security threats; and
• consent where applicable.

5. Sharing of Information

We may share personal data with:

5.1 Service Providers

Including:

• cloud infrastructure providers;
• compliance providers;
• blockchain analytics providers;
• identity verification providers;
• customer support systems; and
• cybersecurity providers.

5.2 Financial Institutions and Payment Providers

Where required for fiat transactions, settlement, banking, or payment processing.

5.3 Authorities and Regulators

Where required by law, regulation, court order, or lawful request.

5.4 Corporate Transactions

In connection with mergers, acquisitions, restructuring, financing, or business transfers.

We do not sell personal data.

6. International Transfers

Your personal data may be processed outside your country of residence.

Where international transfers occur, we implement safeguards intended to comply with applicable data protection laws.

7. Data Retention

We retain personal data only for as long as necessary to:

• provide the Services;
• comply with legal and regulatory obligations;
• maintain AML/CFT records;
• resolve disputes; and
• protect security and integrity.

8. Security

We implement technical and organizational security measures including:

• encryption;
• access controls;
• monitoring systems;
• authentication procedures;
• audit logging; and
• cybersecurity safeguards.

No system can be guaranteed fully secure.

9. Your Rights

Subject to applicable law, you may have rights to:

• access your personal data;
• correct inaccurate data;
• request deletion;
• restrict processing;
• object to processing;
• request portability; and
• withdraw consent where applicable.

Requests may be submitted using the contact details below.

10. Cookies and Tracking Technologies

We may use cookies and similar technologies to:

• maintain functionality;
• improve user experience;
• analyze platform usage; and
• enhance security.

You may manage cookies through browser settings.

11. Third-Party Services

Certain Services may involve third-party providers operating under their own privacy policies and legal frameworks.

Users should review applicable third-party notices before using those services.

12. Changes to this Policy

We may update this Privacy Policy from time to time.

Updated versions may be posted on the website or within the App.

13. Contact Information

This Risk Disclosure describes important risks associated with the use of our applications, websites, APIs, and related services (collectively, the “Services”).

The Services are operated by Paioptimum OÜ (“Paioptimum”, “Company”, “we”, “us”, or “our”), a company incorporated in Estonia and preparing for authorization under the European Union Markets in Crypto-Assets Regulation (“MiCA”) framework.

By accessing or using the Services, you acknowledge and accept that digital assets, blockchain technology, and crypto-asset related services involve significant risks, including the potential loss of value or access to assets.

1. General Risk Warning

Digital assets are volatile and speculative.

You may lose some or all of the value associated with your digital assets.

Past performance is not indicative of future results.

2. Market Risk

• Prices may fluctuate significantly.
• Liquidity may be insufficient.
• Slippage and execution delays may occur.
• Market manipulation may affect asset pricing.
• Trading conditions may change rapidly.

3. Technology and Blockchain Risk

• Blockchain networks may become congested or fail.
• Smart contracts may contain vulnerabilities.
• Transactions are generally irreversible.
• Forks, protocol upgrades, or validator failures may occur.
• Third-party infrastructure may become unavailable.

4. Custody and Access Risk

• Loss of passwords, private keys, or seed phrases may result in permanent loss of access.
• Unauthorized access may occur if credentials or devices are compromised.
• Cyberattacks, phishing, malware, or social engineering may result in losses.

5. Regulatory Risk

• Laws and regulations relating to digital assets may change.
• Certain services may become restricted or prohibited.
• Regulatory authorities may require suspension or limitation of features.
• Availability of Services may differ between jurisdictions.

6. Stablecoin and Token Risk

Certain digital assets may:

• lose their peg or intended value reference;
• become illiquid;
• fail operationally;
• be affected by issuer insolvency; or
• be impacted by regulatory intervention.

7. Third-Party Risk

Certain features may rely on:

• custodians;
• banking partners;
• payment institutions;
• liquidity providers;
• blockchain protocols; or
• other third-party providers.

Paioptimum is not responsible for failures or actions of independent third parties except where required by law.

8. Operational Risk

• Service interruptions may occur.
• Maintenance periods may limit access.
• Technical failures or infrastructure outages may impact transactions.
• Delays may occur due to blockchain congestion or external dependencies.

9. No Financial or Investment Advice

Nothing provided through the Services constitutes:

• investment advice;
• financial advice;
• tax advice;
• legal advice; or
• a recommendation to buy or sell any asset.

Users should seek independent professional advice where appropriate.

10. User Responsibility

You are solely responsible for:

• evaluating risks;
• securing credentials;
• complying with applicable laws;
• assessing transaction suitability; and
• understanding blockchain-related risks.

11. Updates

We may update this Risk Disclosure from time to time.

Continued use of the Services constitutes acceptance of the updated version.

12. Contact Information

The information, materials, features, and services made available through our applications, websites, APIs, and related services (collectively, the “Services”) are provided by Paioptimum OÜ (“Paioptimum”, “Company”, “we”, “us”, or “our”) for general informational and digital asset service purposes only.

Nothing contained in the Services constitutes or should be interpreted as:

• investment advice;
• financial advice;
• legal advice;
• tax advice;
• accounting advice;
• fiduciary services; or
• a recommendation, endorsement, or solicitation to buy, sell, hold, or transact in any digital asset or financial instrument.

Digital assets and blockchain-related services involve significant risk and may not be suitable for all users. The value of digital assets may fluctuate significantly, and users may lose some or all of their assets or associated value.

Paioptimum does not guarantee:

• profitability;
• performance;
• market value;
• liquidity;
• uninterrupted availability;
• transaction execution;
• compatibility with third-party systems; or
• future regulatory treatment of any digital asset or service.

Certain features may involve third-party providers, blockchain protocols, smart contracts, liquidity providers, payment institutions, custodians, or external infrastructure that operate independently from Paioptimum. Paioptimum is not responsible for the acts, omissions, availability, security, or performance of independent third parties except where required by applicable law.

The Services may not be available in all jurisdictions and may be restricted or unavailable depending on applicable laws, regulations, sanctions requirements, risk assessments, or internal compliance policies.

Paioptimum is a company incorporated in Estonia and may be preparing for authorization under applicable European Union regulatory frameworks, including the Markets in Crypto-Assets Regulation (“MiCA”). Nothing on the Services should be interpreted as a representation that any regulatory authorization or license has been granted unless expressly stated through official regulatory disclosures.

Users are solely responsible for:

• evaluating risks associated with digital assets and blockchain technology;
• complying with applicable laws and regulations;
• securing their credentials, devices, private keys, and authentication methods; and
• obtaining independent professional advice where appropriate.

The Services are provided on an “as is” and “as available” basis to the maximum extent permitted by applicable law.